Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 1 of 17 PageID #: 14414
`Case 2:17-cv-00514—JRG Document 161-23 Filed 02/13/19 Page 1 of 17 PageID #: 14414
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`EXHIBIT 22
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`EXHIBIT 22
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`

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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 2 of 17 PageID #: 14415
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`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff,
`
`
`Case No. 2:17-CV-0514-JRG
`(Lead Case)
`
`
`JURY TRIAL DEMANDED
`
`
`
`
`v.
`
`
`HTC CORPORATION., ET AL.,
`
`
`Defendants.
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`
`PLAINTIFF AGIS SOFTWARE DEVELOPMENT LLC’S OBJECTIONS
`AND RESPONSES TO DEFENDANT HTC CORPORATION’S
`SECOND SET OF INTERROGATORIES TO PLAINTIFF (NOS. 16-25)
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`PLEASE TAKE NOTICE that, pursuant to Rules 26 and 33 of the Federal Rules of Civil
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`Procedure, Plaintiff AGIS Software Development LLC (“AGIS” or “Plaintiff”) hereby responds
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`to Defendant HTC Corporation’s (“HTC” or “Defendant”) Second Set of Interrogatories to
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`Plaintiff (Nos. 16-25) in writing, under oath, and in accordance with the following definitions
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`and instructions, within thirty (30) days of the date of service thereof, November 7, 2018. These
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`Interrogatories are continuing in nature and require supplementation in accordance with the
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`Federal Rules of Civil Procedure as follows:
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`These responses are made solely for the purposes of this action, and are made without
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`waiving, or intending to waive, the right at any time to revise, correct, modify, supplement or
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`clarify any response provided herein or the right to object on any proper grounds to the use of
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`these responses, for any purpose in whole or in part, in any subsequent proceedings or any other
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`action. The right to raise any applicable objections at any time is expressly reserved. A response
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`to any Interrogatory herein should not be taken as an admission or acceptance of the existence of
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`

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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 3 of 17 PageID #: 14416
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`any facts set forth or assumed by such interrogatory, or that such response constitutes admissible
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`evidence. The responses herein reflect only the present state of AGIS’s investigation and the
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`present state of discovery. Except as otherwise indicated, an objection and/or response to a
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`specific interrogatory does not imply that facts responsive to the interrogatory exist.
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`GENERAL OBJECTIONS
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`AGIS incorporates by reference the general and specific objections in AGIS’s Objections
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`and Responses to Defendant HTC Corporation’s First Set of Interrogatories to Plaintiff (Nos. 1-
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`15), dated June 18, 2018, and AGIS’s Supplemental Objections and Responses to HTC
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`Corporation’s First Set of Interrogatories (Nos. 1-15), dated August 17, 2018, AGIS’s Second
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`Supplemental Objections and Responses to Defendant HTC Corporation’s First Set of
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`Interrogatories to Plaintiff (Nos. 1-15), dated December 7, 2018.
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`2
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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 4 of 17 PageID #: 14417
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`SPECIFIC OBJECTIONS AND RESPONSES TO DEFENDANT’S
`SECOND SET OF INTERROGATORIES TO PLAINTIFF (NO. 14)
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`INTERROGATORY NO. 16
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`AGIS declared that the applications for each of the ’838, ’055, and ’251 patents were
`subject to the First-to-File provisions of the America Invents Act. See ’838 patent prosecution,
`App. No. 14/529978, April 25, 2016 Applicant Amendment at 15-16 (AGIS stated that “it is
`understood that the present application will be examined under the post-AIA, first-to-file
`provisions of the patent laws”); ’055 patent prosecution, App. No. 14/695233, October 30, 2015
`Applicant Amendment at 13-14 (AGIS stated that “it is understood that the present application
`will be examined under the post-AIA, first-to-file provisions of the patent laws.”); ’251 patent
`prosecution, App. No. 14/633804, November 13, 2015 Applicant Amendment at 10 (AGIS stated
`that “it is understood that the present application will be examined under the post-AIA, first-to-
`file provisions of the patent laws. See MPEP 2159.02 (March 2014).”). AGIS’s Supplemental
`Responses to HTC’s 1st Set of Interrogatories, served on August 17, 2018, state that AGIS will
`rely upon an invention date prior to September 21, 2004 for the ’838, ’055, and ’251 patents but
`patents subject to the First-to-File provisions of the America Invents Act cannot claim earlier
`invention dates. State AGIS’s basis for claiming a pre-filing invention date for the ’838, ’055,
`and ’251 patents in view of AGIS’s representation to the USPTO that the ’838, ’055, and ’251
`patents are subject to the First-to-File provisions of the America Invents Act, which forbids
`claiming a pre-filing invention date.
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`RESPONSE TO INTERROGATORY NO. 16
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`AGIS hereby incorporates the General Objections as if fully set forth herein. AGIS
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`further objects to this Interrogatory as vague, ambiguous, overbroad, unduly burdensome, and
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`not proportional to the needs of the case because the burden or expense of the proposed
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`discovery outweighs its likely benefit. AGIS further objects to this Interrogatory as seeking
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`information that is properly the subject of expert reports before the deadline for such disclosures.
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`AGIS further objects to this Interrogatory to the extent it seeks information protected by the
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`attorney-client privilege, attorney work product doctrine, and/or any other applicable privilege.
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`AGIS further objects to this Interrogatory as vague, overbroad, ambiguous and confusing. AGIS
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`objects to this Interrogatory to the extent it calls for a legal conclusion.
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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 5 of 17 PageID #: 14418
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`AGIS objects to this Interrogatory as overbroad, irrelevant, and unduly burdensome
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`because it seeks information beyond the scope of HTC’s P.R. 3-3 disclosures, i.e., invalidity
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`contentions, which were served on March 15, 2018.
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`AGIS objects to this Interrogatory as seeking information that is not relevant to any
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`claims or defenses of any party to this action, and not proportional to the needs of the case.
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`Notwithstanding its general and specific objections, AGIS answers as follows:
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`AGIS contends that the asserted issued claims of the ’251, ’055, and ’838 Patents are
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`subject to pre-AIA law. For example, the U.S. Patent and Trademark Office examined the ’251
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`patent’s application under pre-AIA law (August 25, 2015 Office Action) and issued the ’251
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`patent after issuing a July 7, 2016 Notice of Allowance which expressly identified the ’251
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`patent’s application as being subject to pre-AIA law [see AIA (First Inventor to File) Status:
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`NO]. While each of the ’251, ’055, and ’838 Patents has an actual filing date of after March 16,
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`2013, each of the issued claims of the ’251, ’055, and ’838 Patents has an effective filing date, as
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`evidenced on the face of each patent, of September 21, 2004. Accordingly, each of the issued
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`claims of the ’251, ’055, and ’838 Patents are subject to pre-AIA law.
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`Discovery in this case is still ongoing and AGIS continues to investigate this matter.
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`AGIS reserves the right to supplement or amend its response to this interrogatory.
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`INTERROGATORY NO. 17
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`Identify all communications made by any representative or individual associated with any
`AGIS Company to any representative or individual associated with HTC Corporation or HTC
`America, Inc. that pre-date June 21, 2017.
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`RESPONSE TO INTERROGATORY NO. 17
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`AGIS hereby incorporates the General Objections as if fully set forth herein. AGIS
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`further objects to this Interrogatory as vague, ambiguous, overbroad, unduly burdensome, and
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`not proportional to the needs of the case because the burden or expense of the proposed
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`4
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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 6 of 17 PageID #: 14419
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`discovery outweighs its likely benefit. AGIS further objects to this Interrogatory to the extent it
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`seeks information protected by the attorney-client privilege, attorney work product doctrine,
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`and/or any other applicable privilege. AGIS further objects to this Interrogatory on the ground it
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`seeks information not within the custody, possession, or control of AGIS. AGIS objects to the
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`term “any AGIS company” as vague, ambiguous, overbroad, and uncertain.
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`AGIS objects to this Interrogatory as overbroad, irrelevant, and unduly burdensome
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`because it seeks information beyond the scope of this case, e.g., “all communications made by
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`any representative or individual associated with any AGIS company to any representative or
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`individual associated with HTC Corporation or HTC America, Inc.”
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`Notwithstanding its general and specific objections, AGIS answers as follows:
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`Discovery in this case is still ongoing and AGIS continues to investigate this matter.
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`AGIS reserves the right to supplement the response to this Interrogatory to identify additional
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`documents pursuant to Fed. R. Civ. P. 33(d).
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`INTERROGATORY NO. 18
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`Describe, in full, the date on which AGIS contends that HTC Corporation received notice
`of each of the ’055, ’251, ’838, and ’970 patents, including: (a) the date of the notice; (b) the
`form that the notice was in (e.g., whether it was a hand-delivered letter, an e-mail, or was made
`verbally, etc.); (c) all documents reflecting the notice; (d) the person who received the notice; (e)
`the person who sent the notice; (f) the patent identified in the notice; and (g) how the notice put
`HTC Corporation on notice of an allegedly infringing act.
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`RESPONSE TO INTERROGATORY NO. 18
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`AGIS hereby incorporates the General Objections as if fully set forth herein.
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`AGIS further objects to this Interrogatory as vague, ambiguous, overbroad, unduly
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`burdensome, and not proportional to the needs of the case because the burden or expense of the
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`proposed discovery outweighs its likely benefit.
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`5
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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 7 of 17 PageID #: 14420
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`AGIS further objects to this Interrogatory to the extent it seeks information protected by
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`the attorney-client privilege, attorney work product doctrine, and/or any other applicable
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`privilege.
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`AGIS objects to this Interrogatory because it is cumulative and/or duplicative of other
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`discovery requests. AGIS further objects to this Interrogatory on the ground it seeks information
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`not within the custody, possession, or control of AGIS.
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`AGIS objects to this Interrogatory as overbroad, irrelevant, and unduly burdensome
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`because it seeks information beyond the scope of HTC’s P.R. 3-3 disclosures, i.e., invalidity
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`contentions and amended invalidity contentions, which were served on March 15, 2018 and May
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`25, 2018, respectively.
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`AGIS objects to this Interrogatory to the extent it calls for a legal conclusion.
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`AGIS objects to this Interrogatory as seeking information that is not relevant to the
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`claims or defenses of any party to this action, and not proportional to the needs of the case.
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`Notwithstanding its general and specific objections, AGIS answers as follows:
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`HTC received notice of the Patents-in-Suit, at least of the date of the Complaint. The
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`Complaint identifies the Patents-in-Suit and the infringing activity HTC has and continues to
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`engage in. Discovery in this case is still ongoing and AGIS continues to investigate this matter.
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`AGIS reserves the right to supplement the answer to this Interrogatory upon the resolution of the
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`above objections.
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`INTERROGATORY NO. 19
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`AGIS has accused Find My Device and Device Manager (Find My Device’s predecessor)
`of infringing the ’970 patent. Find My Device is not installed on any HTC Corporation-made
`phone and Device Manager (Find My Device’s predecessor) and was only available from a
`Google owned and operated website accessible only via a web browser. Explain AGIS’s basis,
`and identify all documents in support of AGIS’s basis, for alleging that HTC Corporation
`directly infringes the ’970 patent.
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`6
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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 8 of 17 PageID #: 14421
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`RESPONSE TO INTERROGATORY NO. 19
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`AGIS hereby incorporates the General Objections as if fully set forth herein. AGIS
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`further objects to this Interrogatory as vague, ambiguous, overbroad, unduly burdensome, and
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`not proportional to the needs of the case because the burden or expense of the proposed
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`discovery outweighs its likely benefit. AGIS further objects to this Interrogatory to the extent it
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`seeks information protected by the attorney-client privilege, attorney work product doctrine,
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`and/or any other applicable privilege.
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`AGIS objects to this interrogatory on the ground it is premature to the extent that
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`discovery is not complete.
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`AGIS objects to this Interrogatory as premature at least to the extent it seeks expert
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`opinion or testimony, and AGIS will not produce such information until the appropriate time
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`under this Court’s scheduling order.
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`AGIS objects to this Interrogatory as seeking information that is properly the subject of
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`expert reports before the deadline for such disclosures.
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`AGIS objects to this Interrogatory to the extent it includes a non-infringement allegation
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`that “Find My Device is not installed on any HTC Corporation-made phone and Device Manager
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`(Find My Device’s predecessor).”
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`Notwithstanding its general and specific objections, AGIS answers as follows:
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`AGIS identifies the following documents from which information responsive to this
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`Interrogatory may be obtained: AGIS Software Development, LLC v. HTC Corporation, 2:17-cv-
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`00514-JRG, Dkt. 1 (E.D. Tex.) (the “Complaint”); see 2018-11-28 Letter Rubino to Bernstein re
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`970 Patent.
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`7
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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 9 of 17 PageID #: 14422
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`AGIS further states that information responsive to this Interrogatory will be produced in
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`AGIS’s expert reports in accordance with this Court’s scheduling order. Discovery in this case is
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`still ongoing and AGIS continues to investigate this matter. AGIS reserves the right to
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`supplement the answer to this Interrogatory upon the resolution of the above objections.
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`Further, the statement “Find My Device is not installed on any HTC Corporation-made
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`phone and Device Manager (Find My Device’s predecessor)” conflicts with statements made
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`during the deposition of Steven Teng and presented in Exhibits 11- See Teng Deposition
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`Transcript at 71:15-74:24; 82:5-85:20; 63:6-19.
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`INTERROGATORY NO. 20
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`HTC Corporation does not make, use, offer to sell, or sell smartphones in the United
`States or import smartphones into the United States. For each of the asserted claims of the ’055,
`’251, ’838, and ’970 patents, separately identify the party or parties that AGIS contends directly
`infringe each patent, and which activity or activities from 35 U.S.C. § 271(a) (i.e., “makes . . .
`within the United States”, “uses . . . within the United States,” “offers to sell . . . within the
`United States,” “sells . . . within the United States,” or “imports into the United States”)
`constitute the infringing acts. Identify the documents that demonstrate these activities.
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`RESPONSE TO INTERROGATORY NO. 20
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`AGIS hereby incorporates the General Objections as if fully set forth herein.
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`AGIS objects to this Interrogatory as vague, ambiguous, overbroad, unduly burdensome,
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`and not proportional to the needs of this case because the burden or expense of the proposed
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`discovery outweighs its likely benefit.
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`AGIS objects to this Interrogatory to the extent it seeks information protected by the
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`attorney-client privilege, attorney work product doctrine, and/or any other applicable privilege.
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`AGIS objects to this Interrogatory on the ground it seeks information that is the topic of
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`expert discovery.
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`AGIS objects to this Interrogatory as seeking information that is properly the subject of
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`expert reports before the deadline for such disclosures.
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`8
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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 10 of 17 PageID #: 14423
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`AGIS objects to this Interrogatory to the extent it calls for a legal conclusion.
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`AGIS objects to this Interrogatory because it is cumulative and duplicative as it seeks the
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`discovery of information that HTC has already obtained through AGIS’s Disclosure of Asserted
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`Claims and Infringement Contentions pursuant to P.R. 3-1.
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`Subject to and without waiving its general and specific objections, AGIS incorporates by
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`reference as if fully set forth herein its Disclosure of Asserted Claims and Infringement
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`Contentions and Amended Disclosure of Asserted Claims and Infringement Contentions, served
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`on January 19, 2018 and May 25, 2018, respectively. AGIS will supplement its response to this
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`Interrogatory, if necessary, once the Court and/or the parties clarify the scope of the claims by
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`virtue of the claim construction process.
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`INTERROGATORY NO. 21
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`Explain AGIS’s basis, and identify all documents in support of AGIS’s basis, for
`contending that HTC Corporation induces others to infringe each of the ’055, ’251, ’838, and
`’970 patents under 35 U.S.C. § 271(b), including an identification of the party or parties that
`perform the alleged direct infringement and an identification of the activities conducted by HTC
`Corporation that you claim demonstrate a specific intent of HTC Corporation to encourage direct
`infringement, including HTC Corporation’s knowledge of the ’055, ’251, ’838, and ’970 patents,
`knowledge that the induced acts constitute direct infringement of the ’055, ’251, ’838, and ’970
`patents, and the affirmative steps taken by HTC Corporation to bring about direct infringement.
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`RESPONSE TO INTERROGATORY NO. 21
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`AGIS hereby incorporates the General Objections as if fully set forth herein.
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`AGIS objects to this Interrogatory as vague, ambiguous, overbroad, unduly burdensome,
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`and not proportional to the needs of this case because the burden or expense of the proposed
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`discovery outweighs its likely benefit.
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`AGIS objects to this Interrogatory to the extent it seeks information protected by the
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`attorney-client privilege, attorney work product doctrine, and/or any other applicable privilege.
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`9
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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 11 of 17 PageID #: 14424
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`AGIS objects to this Interrogatory on the ground it seeks information that is the topic of
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`expert discovery.
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`AGIS objects to this Interrogatory as seeking information that is properly the subject of
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`expert reports before the deadline for such disclosures.
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`AGIS objects to this Interrogatory to the extent it calls for a legal conclusion.
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`AGIS objects to this Interrogatory because it is cumulative and duplicative as it seeks the
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`discovery of information that HTC has already obtained through AGIS’s Disclosure of Asserted
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`Claims and Infringement Contentions pursuant to P.R. 3-1.
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`AGIS identifies the following documents from which information responsive to this
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`Interrogatory may be obtained: AGIS Software Development, LLC v. HTC Corporation, 2:17-cv-
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`00514-JRG, Dkt. 1 (E.D. Tex. June 21, 2017) (the “Complaint”); see 2018-11-28 Letter Rubino
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`to Bernstein re 970 Patent.
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`AGIS further states that information responsive to this Interrogatory will be produced in
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`AGIS’s expert reports in accordance with this Court’s scheduling order. Discovery in this case is
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`still ongoing and AGIS continues to investigate this matter. AGIS reserves the right to
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`supplement the answer to this Interrogatory upon the resolution of the above objections.
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`INTERROGATORY NO. 22
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`Claims 1 and 54 of the ’838 patent require the following claim limitations:
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`“participating in the group, wherein participating in the group includes sending
`first location information to a first server and receiving second location
`information from the first server”
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`and
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`“sending, to a second server, a request for second georeferenced map data
`different from the first georeferenced map data”
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`Identify: (a) whether AGIS alleges that an HTC Corporation-made phone or a server performs
`the “sending, to a second sever;” (b) what accused instrumentality AGIS contends is the claimed
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`10
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`“first server;” and (c) what accused instrumentality AGIS contends is the claimed “second
`server.”
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`RESPONSE TO INTERROGATORY NO. 22
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`AGIS hereby incorporates the General Objections as if fully set forth herein.
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`AGIS objects to this Interrogatory as vague, ambiguous, overbroad, unduly burdensome,
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`and not proportional to the needs of this case because the burden or expense of the proposed
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`discovery outweighs its likely benefit.
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`AGIS objects to this Interrogatory to the extent it seeks information protected by the
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`attorney-client privilege, attorney work product doctrine, and/or any other applicable privilege.
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`AGIS objects to this Interrogatory on the ground it seeks information that is the topic of
`
`expert discovery.
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`AGIS objects to this Interrogatory as seeking information that is properly the subject of
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`expert reports before the deadline for such disclosures.
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`AGIS objects to this Interrogatory to the extent it calls for a legal conclusion.
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`AGIS objects to this Interrogatory because it is cumulative and duplicative as it seeks the
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`discovery of information that HTC has already obtained through AGIS’s Disclosure of Asserted
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`Claims and Infringement Contentions pursuant to P.R. 3-1.
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`Subject to and without waiving its general and specific objections, AGIS incorporates by
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`reference as if fully set forth herein its Disclosure of Asserted Claims and Infringement
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`Contentions and Amended Disclosure of Asserted Claims and Infringement Contentions, served
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`on January 19, 2018 and May 25, 2018, respectively. AGIS will supplement its response to this
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`Interrogatory, if necessary, once the Court and/or the parties clarify the scope of the claims by
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`virtue of the claim construction process.
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`11
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`INTERROGATORY NO. 23
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`Explain AGIS’s basis, and identify all documents in support of AGIS’s basis, for stating
`that consumers attribute value to those features of Find My Device and Google Maps that
`allegedly infringe the ’055, ’251, ’838, and ’970 patents when the consumers purchase or
`determine to purchase an HTC Corporation-made phone and a quantifiable value attributable to
`said allegedly infringing features for each of the ’055, ’251, ’838, and ’970 patents.
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`RESPONSE TO INTERROGATORY NO. 23
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`AGIS hereby incorporates the General Objections as if fully set forth herein.
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`AGIS objects to this Interrogatory as vague, ambiguous, overbroad, unduly burdensome,
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`and not proportional to the needs of this case because the burden or expense of the proposed
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`discovery outweighs its likely benefit.
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`AGIS objects to this Interrogatory to the extent it seeks information protected by the
`
`attorney-client privilege, attorney work-product doctrine, and/or any other applicable privilege.
`
`AGIS objects to this interrogatory on the ground it is premature to the extent that
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`discovery is not complete
`
`AGIS objects to this Interrogatory as premature at least to the extent it seeks expert
`
`opinion or testimony, and AGIS will not produce such information until the appropriate time
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`under this Court’s scheduling order.
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`AGIS objects to this Interrogatory as seeking information that is properly the subject of
`
`expert reports before the deadline for such disclosures.
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`Subject to and without waiving its general and specific objections, AGIS states that
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`information responsive to this Interrogatory will be produced in AGIS’s expert reports in
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`accordance with this Court’s scheduling order.
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`INTERROGATORY NO. 24
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`State the basis for AGIS’s contention that it is entitled to an injunction, including without
`limitation (1) how AGIS has suffered irreparable injury as a result of HTC Corporation’s alleged
`infringement, including an identification of the relevant market and the presence or absence of
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`12
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`other competitors in the relevant market; (2) why monetary damages are inadequate to
`compensate for such injury; (3) the hardship AGIS would suffer were an injunction to be denied
`and why it is greater than the hardship HTC would suffer should an injunction be granted; and
`(4) how the public interest would be served by such an injunction. Identify all documents
`supporting AGIS’s contention that it is entitled to an injunction.
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`RESPONSE TO INTERROGATORY NO. 24
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`AGIS hereby incorporates the General Objections as if fully set forth herein.
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`AGIS objects to this Interrogatory as vague, ambiguous, overbroad, unduly burdensome,
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`and not proportional to the needs of this case because the burden or expense of the proposed
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`discovery outweighs its likely benefit.
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`AGIS objects to this Interrogatory to the extent it seeks information protected by the
`
`attorney-client privilege, attorney work-product doctrine, and/or any other applicable privilege.
`
`AGIS objects to this Interrogatory on the ground it seeks information that is the topic of
`
`expert discovery.
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`AGIS objects to this Interrogatory as seeking information that is properly the subject of
`
`expert reports before the deadline for such disclosures.
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`Subject to and without waiving its general and specific objections, AGIS states that
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`information responsive to this Interrogatory can be found in AGIS Complaint.
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`INTERROGATORY NO. 25
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`State the date on which AGIS contends that the hypothetical negotiation between AGIS
`and HTC Corporation should take place and AGIS’s basis for choosing said date.
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`RESPONSE TO INTERROGATORY NO. 25
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`AGIS hereby incorporates the General Objections as if fully set forth herein.
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`AGIS objects to this Interrogatory as vague, ambiguous, overbroad, unduly burdensome,
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`and not proportional to the needs of this case because the burden or expense of the proposed
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`discovery outweighs its likely benefit.
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`13
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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 15 of 17 PageID #: 14428
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`AGIS objects to this Interrogatory to the extent it seeks information protected by the
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`attorney-client privilege, attorney work-product doctrine, and/or any other applicable privilege.
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`AGIS objects to this interrogatory on the ground it is premature to the extent that
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`discovery is not complete
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`AGIS objects to this Interrogatory as premature at least to the extent it seeks expert
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`opinion or testimony, and AGIS will not produce such information until the appropriate time
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`under this Court’s scheduling order.
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`AGIS objects to this Interrogatory as seeking information that is properly the subject of
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`expert reports before the deadline for such disclosures.
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`Subject to and without waiving its general and specific objections, AGIS states that
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`information responsive to this Interrogatory will be produced in AGIS’s expert reports in
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`accordance with this Court’s scheduling order.
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`
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`Dated: December 7, 2018
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`As to Objections,
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`BROWN RUDNICK LLP
`
` /s/ Vincent J. Rubino III
`
`
`
`Alfred R. Fabricant
`NY Bar No. 2219392
`Email: afabricant@brownrudnick.com
`Lawrence C. Drucker
`NY Bar No. 2303089
`Email: ldrucker@brownrudnick.com
`Peter Lambrianakos
`NY Bar No. 2894392
`Email: plambrianakos@brownrudnick.com
`Vincent J. Rubino, III
`NY Bar No. 4557435
`Email: vrubino@brownrudnick.com
`Alessandra C. Messing
`NY Bar No. 5040019
`Email: amessing@brownrudnick.com
`
`
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`14
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`

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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 16 of 17 PageID #: 14429
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`
`
`
`
`Shahar Harel
`NY Bar No. 4573192
`Email: sharel@brownrudnick.com
`John A. Rubino
`NY Bar No. 5020797
`Email: jrubino@brownrudnick.com
`Enrique W. Iturralde
`NY Bar No. 5526280
`Email: eiturralde@brownrudnick.com
`Daniel J. Shea, Jr.
`NY Bar No. 5430558
`Email: dshea@brownrudnick.com
`Justine Minseon Park
`NY Bar No. 5604483
`Email: apark@brownrudnick.com
`BROWN RUDNICK LLP
`7 Times Square
`New York, NY 10036
`Telephone: 212-209-4800
`Facsimile: 212-209-4801
`
`Samuel F. Baxter
`Texas Bar No. 01938000
`Email: sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`Email: jtruelove@mckoolsmith.com
`McKOOL SMITH, P.C.
`104 East Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: 903-923-9000
`Facsimile: 903-923-9099
`
`ATTORNEYS FOR PLAINTIFF, AGIS
`SOFTWARE DEVELOPMENT LLC
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`
`15
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`

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`Case 2:17-cv-00514-JRG Document 161-23 Filed 02/13/19 Page 17 of 17 PageID #: 14430
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`CERTIFICATE OF SERVICE
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`I hereby certify that on December 7, 2018, a true and correct copy of the above and
`
`foregoing document has been served by email on:
`
`Matthew C. Bernstein
`mbernstein@perkinscoie.com
`PERKINS COIE LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130-2594
`
`Eric Hugh Findlay
`efindlay@findlaycraft.com
`FINDLAY CRAFT PC
`102 N. College Avenue, Suite 900
`Tyler, Texas 75702
`
`Brian Craft
`bcraft@findlaycraft.com
`FINDLAY CRAFT PC
`102 N. College Avenue, Suite 900
`Tyler, Texas 75702
`
`James Y. Hurt
`jhurt@perkinscoie.com
`PERKINS COIE LLP
`11988 El Camino Real, Suite 350
`San Diego, CA 92130-2594
`
`Miguel Jose Bombach
`mbombach@perkinscoie.com
`PERKINS COIE LLP - San Diego
`11988 El Camino Real, Suite 350
`San Diego, CA 92130-3334
`
`Kyle Ryan Canavera
`kcanavera@perkinscoie.com
`PERKINS COIE LLP - San Diego
`11988 El Camino Real, Suite 350
`San Diego, CA 92130-3334
`
`Attorneys for Defendant HTC Corporation
`
` /s/ Vincent J. Rubino III
`
` Vincent J. Rubino III
`
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`