`
`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
`
`§§§§§§§§§
`
`§§§§§§§§§
`
`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 MOTIONS IN LIMINE NOS. 1–6
`
`I, Nicholas H. Lee, state and declare as follows:
`
`1.
`
`I am a partner of Arnold & Porter Kaye Scholer LLP, counsel of record for
`
`Defendant LG Electronics Inc. (“LG Korea”). 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 Korea’s
`
`Motions In Limine Nos. 1–6. I have personal knowledge of the matters stated in this declaration
`
`and would testify competently and truthfully to them if called upon to do so.
`
`1
`
`
`
`Case 2:17-cv-00514-JRG Document 169-1 Filed 02/13/19 Page 2 of 3 PageID #: 14944
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of excerpts of Exhibit A to
`
`AGIS’s Infringement Contentions regarding U.S. Patent No. 8,213,970, dated December 19,
`
`2018.
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of excerpts of Exhibit B to
`
`AGIS’s Infringement Contentions regarding U.S. Patent No. 9,408,055, dated November 28,
`
`2017.
`
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of excerpts of Exhibit C to
`
`AGIS’s Infringement Contentions regarding U.S. Patent No. 9,445,251, dated November 28,
`
`2017.
`
`5.
`
`Attached hereto as Exhibit 4 is a true and correct copy of excerpts of Exhibit D to
`
`AGIS’s Infringement Contentions regarding U.S. Patent No. 9,467,838, dated November 28,
`
`2017.
`
`6.
`
`Attached hereto as Exhibit 5 is a true and correct copy of Attachment A to Mr.
`
`McAlexander’s December 14, 2018 report regarding Findings of LG Product Infringement of
`
`8,213,970 Patent Claims.
`
`7.
`
`Attached hereto as Exhibit 6 is a true and correct copy of Attachment B to Mr.
`
`McAlexander’s December 14, 2018 report regarding Findings of LG Product Infringement of
`
`9,408,055 Patent Claims.
`
`8.
`
`Attached hereto as Exhibit 7 is a true and correct copy of Attachment C to Mr.
`
`McAlexander’s December 14, 2018 report regarding Findings of LG Product Infringement of
`
`9,445,251 Patent Claims.
`
`2
`
`
`
`Case 2:17-cv-00514-JRG Document 169-1 Filed 02/13/19 Page 3 of 3 PageID #: 14945
`
`9.
`
`Attached hereto as Exhibit 8 is a true and correct copy of Attachment D to Mr.
`
`McAlexander’s December 14, 2018 report regarding Findings of LG Product Infringement of
`
`9,467,838 Patent Claims.
`
`10.
`
`Attached hereto as Exhibit 9 is a true and correct copy of excerpts of the Expert
`
`Report of Joseph C. McAlexander III Regarding Infringement of U.S. Patent Numbers:
`
`8,213,970; 9,408,055; 9,445,251; and 9,467,838, dated December 14, 2018.
`
`11.
`
`Attached hereto as Exhibit 10 is a true and correct copy of AGIS’s Notice of
`
`Subpoena to Google LLC and Subpoena to Produce Documents, Information, Or Objects Or To
`
`Permit Inspection Of Premises In A Civil Action, served on August 29, 2018.
`
`12.
`
`Attached hereto as Exhibit 11 is a true and correct copy of excerpts of Plaintiff
`
`AGIS Software Development LLC’s Supplemental Objections and Responses to Defendant LG
`
`Electronics Inc.’s First Set of Interrogatories to Plaintiff (Nos. 1-13), served on December 6,
`
`2018.
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed in Los
`
`Angeles, California on February 11, 2019.
`
`Nicholas H. Lee
`/s/
`Nicholas H. Lee
`Attorney for Defendant LG Electronics Inc.
`
`3
`
`