`
`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
`
`CASE NO. 2:17-CV-515-JRG
`(Member Case)
`
`JURY TRIAL DEMANDED
`
`§§§§§§§§§
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`§§§§§§§§§
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`AGIS SOFTWARE DEVELOPMENT, LLC
`
`Plaintiff,
`
`v.
`
`HTC CORPORATION, et al.
`
`Defendant.
`AGIS SOFTWARE DEVELOPMENT, LLC
`
` Plaintiff,
`
`v.
`
`LG ELECTRONICS INC.
`
` Defendant.
`
`DECLARATION OF NICHOLAS H. LEE IN SUPPORT OF DEFENDANT LG
`ELECTRONICS INC.’S OPPOSITION TO AGIS’S MOTION TO STRIKE THE
`JANUARY 11, 2019 EXPERT REPORT OF EDWARD R. TITTEL
`
`I, Nicholas H. Lee, state and declare as follows:
`
`1.
`
`I am a member of Arnold & Porter Kaye Scholer, LLP (“Arnold & Porter”),
`
`counsel of record for Defendant LG Electronics Inc. (“LG”). I am a member of the Bar of the
`
`State of California and have been admitted to practice in the United States District Court for the
`
`Eastern District of Texas (“EDTX”). I provide this declaration in support of Defendant LG’s
`
`Opposition to AGIS’s Motion to Strike the January 11, 2019 Expert Report of Edward R. Tittel.
`
`I have personal knowledge of the matters stated in this declaration and would testify competently
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`and truthfully to them if called upon to do so.
`
`1
`
`
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`Case 2:17-cv-00514-JRG Document 166-9 Filed 02/13/19 Page 2 of 2 PageID #: 14836
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`2.
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`Attached hereto as Exhibit A is a true and correct copy of LG’s Initial
`
`Disclosures, served on AGIS on December 22, 2017.
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`3.
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`Attached hereto as Exhibit B is a true and correct copy of AGIS’s Initial
`
`Disclosures, served on LG on December 22, 2017.
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`4.
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`Attached hereto as Exhibit C is a true and correct copy of excerpts of the Rebuttal
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`Expert Report of Edward R. Tittel, served on AGIS on January 11, 2019.
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`5.
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`Attached hereto as Exhibit D is a true and correct copy of LG’s Initial
`
`Disclosures, served on AGIS on January 11, 2019.
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed in Los
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`Angeles, California on February 11, 2019.
`
`/s/ Nicholas H. Lee
`Nicholas H. Lee
`Attorney for Defendant LG Electronics Inc.
`
`
`
`2
`
`