`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`CASE NO. 2:17-CV-514-JRG
`(LEAD CASE)
`
`JURY TRIAL DEMANDED
`
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff,
`
`vs.
`
`HTC CORPORATION,
`
`Defendant.
`
`
`DECLARATION OF MIGUEL J. BOMBACH
`IN SUPPORT OF DEFENDANT HTC CORPORATION’S
`MOTIONS IN LIMINE NOS. 1-12
`
`
`
`
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`
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`Case 2:17-cv-00514-JRG Document 163-1 Filed 02/13/19 Page 2 of 3 PageID #: 14570
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`
`
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`I, Miguel J. Bombach, hereby declare as follows:
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`1.
`
`I am an attorney at the law firm of Perkins Coie LLP and counsel of record for
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`HTC Corporation (“HTC Corp.”) in the above entitled matter. I am a member of good standing
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`of the California and United States Patent and Trademark Bar and am admitted to practice in the
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`Eastern District of Texas.
`
`2.
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`3.
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`I make this declaration in support of HTC Corp.’s Motions in Limine Nos. 1-12.
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`Attached hereto as Exhibit 1 is a true and correct copy of excerpts of Attachment
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`A to the expert report of Joseph C. McAlexander.
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`4.
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`Attached hereto as Exhibit 2 is a true and correct copy of excerpts of Attachment
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`B to the expert report of Joseph C. McAlexander.
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`5.
`
`Attached hereto as Exhibit 3 is a true and correct copy of excerpts of Attachment
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`C to the expert report of Joseph C. McAlexander.
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`6.
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`Attached hereto as Exhibit 4 is a true and correct copy of excerpts of Attachment
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`D to the expert report of Joseph C. McAlexander.
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`7.
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`Attached hereto as Exhibit 5 is a true and correct copy of excerpts of the
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`deposition of Dr. Andrew Wolfe, taken on February 1, 2019.
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`8.
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`Attached hereto as Exhibit 6 is a true and correct copy of an email from Enrique
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`W. Iturralde (who represents AGIS) regarding AGIS receiving a production of source code from
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`Google, dated January 24, 2019.
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`9.
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`Attached hereto as Exhibit 7 is a true and correct copy of Plaintiff’s Disclosure of
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`Asserted Claims and Infringement Contentions, dated December 19, 2018.
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`10.
`
`Attached hereto as Exhibit 8 is a true and correct copy of excerpts of the Expert
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`Report of Dr. Andrew Wolfe, dated January 11, 2019.
`
`1
`
`
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`Case 2:17-cv-00514-JRG Document 163-1 Filed 02/13/19 Page 3 of 3 PageID #: 14571
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`
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`
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`Attached hereto as Exhibit 9 is a true and correct copy of the Notice of Subpoenas
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`11.
`
`to Google LLC by AGIS Software Development, LLC, dated August 29, 2018.
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`12.
`
`Attached hereto as Exhibit 10 is a true and correct copy of excerpts of a letter
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`from Miguel Bombach to Alessandra Messing, dated May 16, 2018.
`
`13.
`
`Attached hereto as Exhibit 11 is a true and correct copy of excerpts of an email
`
`from Enrique W. Iturralde to Miguel Bombach regarding source code review, dated October 2,
`
`2018.
`
`14.
`
`Attached hereto as Exhibit 12 is a true and correct copy of excerpts of the Expert
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`Report of Joseph C. McAlexander, dated December 14, 2018.
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`15.
`
`Attached hereto as Exhibit 13 is a true and correct copy of excerpts of the Expert
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`Report of Alan Ratliff, dated December 14, 2018.
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`16.
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`Attached hereto as Exhibit 14 is a true and correct copy of excerpts of the
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`deposition of Alan Ratliff, dated January 24, 2019.
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`17.
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`Attached hereto as Exhibit 15 is a true and correct copy of excerpts of the
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`deposition of Malcolm Keller Beyer, Jr., taken on October 22 and October 23, 2018.
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`18.
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`Attached hereto as Exhibit 16 is a true and correct copy of excerpts of
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`Defendant’s Notice of Deposition of AGIS Software Development LLC pursuant to Rule
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`30(B)(6), dated July 27, 2018.
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`19.
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`Attached hereto as Exhibit 17 is a true and correct copy of excerpts of an email
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`from Enrique W. Iturralde, dated September 21, 2018.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 11th day of February, 2019, in San Diego, California.
`
`/s/ Miguel J. Bombach
`Miguel J. Bombach
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`2
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