`Case 2:17-cv-00514-JRG Document 165-1 Filed 02/13/19 Page 1 of 2 PageID #: 14645
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`CASE NO. 2:17-cv-514—JRG
`(LEAD CASE)
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`JURY TRIAL DEMANDED
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`CASE NO. 2: l7-CV-515-JRG
`(CONSOLIDATED CASE)
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`JURY TRIAL DEMANDED
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`AGIS SOFTWARE DEVELOPMENT, LLC
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`Plaintiff,
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`V.
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`HTC CORPORATION, et al.
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`Defendant.
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`AGIS SOFTWARE DEVELOPMENT, LLC
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`Plaintiff,
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`V.
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`LG ELECTRONICS INC.
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`Defendant.
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`DECLARATION OF JUSTIN CHI IN SUPPORT OF LG ELECTRONICS INC.’S
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`OPPOSITION TO AGIS SOFTWARE DEVELOPMENT LLC’S DA UBERT MOTION
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`TO EXCLUDE THE OPINIONS OF W. CHRISTOPHER BAKEWELL
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`1, Justin Chi, state and declare as follows:
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`1.
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`I am an attorney with Arnold & Porter Kaye Scholer LLP (“APKS”), counsel of
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`record for Defendant LG Electronics Inc. (“LGEKR”).
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`I am a member of the Bar of the State of
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`Texas and have been admitted to practice in the United States District Court for the Eastern
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`District of Texas.
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`I provide this declaration in support ofDefendant LGEKR’S opposition to
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`AGIS Software Development LLC’S (“AGIS”) Daubert motion to exclude the opinions of W.
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`Christopher Bakewell relating to damages.
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`I have personal knowledge of the matters stated in
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`this declaration and would testify competently and truthfully to them if called upon to do so.
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`1
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`Case 2:17-cv-00514-JRG Document 165-1 Filed 02/13/19 Page 2 of 2 PageID #: 14646
`Case 2:17-cv-00514-JRG Document 165-1 Filed 02/13/19 Page 2 of 2 PageID #: 14646
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`2.
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`Attached hereto as Exhibit A is a true and correct copy of excerpts of Mr. W.
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`Christopher Bakewell’s Rebuttal Expert Report Regarding Damages, dated January 11, 2019.
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`As recommended in Local Rule CV-7(b), relevant, cited-to portions have been highlighted in this
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`copy for the Court.
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`3.
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`Attached hereto as Exhibit B is a true and correct copy of a workpaper submitted
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`with the supplemental exhibits and workpapers in support of the expert report of AGIS’s
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`damages expert, Mr. Alan Ratliff, entitled “StoneTurn Workpaper 13.” As recommended in
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`Local Rule CV-7(b), relevant, cited—to portions have been highlighted in this copy for the Court.
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`4.
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`Attached hereto as Exhibit C is a true and correct copy of excerpts of the
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`Damages Expert Report of Alan Ratliff on Behalf of AGIS With Respect To LG Electronics Inc.
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`and a workpaper submitted with the exhibits and workpapers in support of Mr. Ratliff’s expert
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`report, entitled “StoneTurn Workpaper 12.”
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`I declare under penalty of perjury that the foregoing is true and correct. Executed on this
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`1 1th day of February 2019 in Houston, Texas.
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`Justin Chi
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