`Case 2:17-cv-00514-JRG Document 175-3 Filed 02/18/19 Page 1 of 6 PageID #: 15091
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`EXHIBIT B
`EXHIBIT B
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`Case 2:17-cv-00514-JRG Document 175-3 Filed 02/18/19 Page 2 of 6 PageID #: 15092
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`Plaintiff,
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`v.
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`HTC CORPORATION,
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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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`Case No. 2:17-cv-00514-JRG
`(Lead Case)
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`JURY TRIAL DEMANDED
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`Case No. 2:17-cv-00515-JRG
`(Member Case)
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`JURY TRIAL DEMANDED
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`LG ELECTRONICS INC.’S AMENDED REBUTTAL PRETRIAL DISCLOSURES
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`Case 2:17-cv-00514-JRG Document 175-3 Filed 02/18/19 Page 3 of 6 PageID #: 15093
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`Pursuant to the Court’s Fourth Amended Docket Control Order (D.I. 141) entered on
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`February 1, 2019, Defendant LG Electronics Inc. (“Defendant” or “LG Korea”) hereby serves
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`the following amended rebuttal pretrial disclosures to Plaintiff AGIS Software Development
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`LLC (“Plaintiff” or “AGIS”).
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`For purposes of rebuttal, Defendant LG Korea identifies, incorporates by reference, and
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`reserves the right to rely upon the following disclosures, all of which were served to AGIS on
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`February 8, 2019:
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`• LG Electronics Inc.’s List of Trial Witnesses
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`• LG Electronics Inc.’s Deposition Designations
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`• Attachment A to LG Electronics Inc.’s Deposition Designations
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`• LG Electronics Inc.’s Trial Exhibit List
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`In addition, for rebuttal purposes, and to the extent necessary, Defendant identifies Apple,
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`Inc., and reserves the right to identify a witness from Apple, Inc. most knowledgeable on
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`settlement terms with AGIS related to AGIS Software Development, LLC v. Huawei USA Inc. et
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`al., Case No. 2:17-cv-0513-JRG (E.D. Tex.) (lead case); AGIS Software Development, LLC v.
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`Apple, Inc., Case No. 2:17-cv-0516-JRG (E.D. Tex.) (member case).
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`Defendant reserves the right to amend, supplement, or otherwise modify any of these
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`disclosures for purposes of rebuttal issues leading up to and during trial. Defendant further
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`reserves the right to challenge any use by AGIS of any of the identifications made in the above-
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`identified disclosures, and does not waive any objections to AGIS’s attempted use of any such
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`identifications, exhibits, or designations.
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`2
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`Case 2:17-cv-00514-JRG Document 175-3 Filed 02/18/19 Page 4 of 6 PageID #: 15094
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`Dated: February 14, 2019
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`Respectfully submitted,
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`
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`By:
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`/s/ Michael A. Berta
`J. Mark Mann
`SBN: 12926150
`G. Blake Thompson
`SBN: 24042033
`MANN TINDEL THOMPSON
`300 West Main Street
`Henderson, Texas 75652
`Tel: (903) 657-8540
`mark@themannfirm.com
`blake@themannfirm.com
`
`Michael A. Berta
`ARNOLD & PORTER KAYE SCHOLER
`LLP
`Three Embarcadero Center
`10th Floor
`San Francisco, CA 94111-4024
`Tel: (415) 471-3277
`Michael.Berta@arnoldporter.com
`
`James S. Blackburn
`Nicholas H. Lee
`Justin J. Chi
`ARNOLD & PORTER KAYE SCHOLER
`LLP
`777 South Figueroa Street
`44th Floor
`Los Angeles, CA 90017-5844
`Tel: (213) 243-4156
`James.Blackburn@arnoldporter.com
`Nicholas.Lee@arnoldporter.com
`Justin.Chi@arnoldporter.com
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`3
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`Case 2:17-cv-00514-JRG Document 175-3 Filed 02/18/19 Page 5 of 6 PageID #: 15095
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`Bonnie Phan
`ARNOLD & PORTER KAYE SCHOLER
`LLP
`3000 El Camino Real
`Five Palo Alto Square
`Suite 500
`Palo Alto, CA 94306-3807
`Tel: (650) 319-4500
`Bonnie.Phan@arnoldporter.com
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`Attorneys for Defendant LG Electronics,
`Inc.
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`4
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`Case 2:17-cv-00514-JRG Document 175-3 Filed 02/18/19 Page 6 of 6 PageID #: 15096
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that all counsel of record who are deemed to have
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`consented to electronic service are being served with a copy of this document via electronic mail
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`on February 14, 2019.
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`/s/ Bonnie Phan
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`
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`
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`Bonnie Phan
`ARNOLD & PORTER KAYE SCHOLER LLP
`3000 El Camino Real
`Five Palo Alto Square, Suite 500
`Palo Alto, CA 94306-2112
`Tel: 1 650.319.4543
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`5
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