`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`
`Plaintiff,
`
`
`
`v.
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
`
`§
`Case No. 2:17-CV-0514-JRG
`§
`(LEAD CASE)
`§
`
`§
`JURY TRIAL DEMANDED
`§
`
`§
`§
`§
`§
`
`
`HTC CORPORATION,
`
`
`Defendant.
`
`
`
`LG ELECTRONICS INC.,
`
`
`Defendant.
`
`Case No. 2:17-CV-0515-JRG
`(CONSOLIDATED CASE)
`
`JURY TRIAL DEMANDED
`
`§
`§
`§
`§
`
`
`DECLARATION OF ALFRED R. FABRICANT IN SUPPORT OF
`PLAINTIFF AGIS SOFTWARE DEVELOPMENT, LLC’S
`RESPONSE IN OPPOSITION TO LG ELECTRONICS INC.’S
`SEALED MOTION FOR SUMMARY JUDGMENT
`OF NON-INFRINGEMENT OF U.S. PATENT NO. 8,213,970 (DKT. 112)
`
`
`
`I, Alfred R. Fabricant, hereby declare as follows:
`
`1.
`
`I am a member of Brown Rudnick LLP, lead counsel of record for Plaintiff AGIS
`
`Software Development LLC (“AGIS”). I am admitted to practice before this Court. I submit this
`
`declaration in support of AGIS Software Development LLC’s Response in Opposition to LG
`
`Electronics Inc.’s Sealed Motion for Summary Judgment of Non-Infringement of U.S. Patent No.
`
`8,213,970 (Dkt. 112). I am familiar with the facts set forth herein.
`
`2.
`
`The exhibits attached to this declaration may contain annotations and/or excerpts
`
`of the originals.
`
`3.
`
`Attached hereto as Exhibit A is a true and correct copy of
`
`
`
`
`
`
`
`Case 2:17-cv-00514-JRG Document 214-1 Filed 02/21/19 Page 2 of 3 PageID #: 18343
`
`4.
`
`Attached hereto as Exhibit B is a true and correct copy of Attachment A to the
`
`Expert Report of Joseph McAlexander, dated December 14, 2018.
`
`5.
`
`Attached hereto as Exhibit C is a true and correct copy of annotated excerpts of the
`
`Expert Report of Joseph McAlexander, dated December 14, 2018.
`
`6.
`
`Attached hereto as Exhibit D is a true and correct copy of Exhibit 7 to the February
`
`15, 2019 Deposition of Edward Tittel.
`
`7.
`
`Attached hereto as Exhibit E is a true and correct copy of Exhibit 8 to the February
`
`15, 2019 Deposition of Edward Tittel.
`
`8.
`
`Attached hereto as Exhibit F is a true and correct copy of Exhibit 9 to the February
`
`15, 2019 Deposition of Edward Tittel.
`
`9.
`
`Attached hereto as Exhibit G is a true and correct copy of Exhibit 10 to the
`
`February 15, 2019 Deposition of Edward Tittel.
`
`10.
`
`Attached hereto as Exhibit H is a true and correct copy of Exhibit 11 to the
`
`February 15, 2019 Deposition of Edward Tittel.
`
`11.
`
`Attached hereto as Exhibit I is a true and correct copy of Exhibit 6 to the February
`
`15, 2019 Deposition of Edward Tittel.
`
`12.
`
`Attached hereto as Exhibit J is a true and correct copy of
`
`
`
`13.
`
`Attached hereto as Exhibit K is a true and correct copy of
`
`
`
`
`
`
`
`14.
`
`Attached hereto as Exhibit L is a true and correct copy of Exhibit 2 to the February
`
`15, 2019 Deposition of Edward Tittel.
`
`2
`
`
`
`Case 2:17-cv-00514-JRG Document 214-1 Filed 02/21/19 Page 3 of 3 PageID #: 18344
`
`15.
`
`Attached hereto as Exhibit M is a true and correct copy of Exhibit 3 to the February
`
`15, 2019 Deposition of Edward Tittel.
`
`16.
`
`Attached hereto as Exhibit N is a true and correct copy of annotated excerpts of the
`
`Rebuttal Expert Report of Edward Tittel, dated January 11, 2019.
`
`17.
`
`Attached hereto as Exhibit O (Parts I - III) is a true and correct copy of
`
`
`
`18.
`
`Attached hereto as Exhibit P is a true and correct copy of
`
`
`
`19.
`
`Attached hereto as Exhibit Q is a true and correct copy of
`
`
`
`
`
`
`
`
`
`
`
`I declare under penalty of perjury that the foregoing is true and correct to the best of my
`
`knowledge. Executed on February 19, 2019.
`
` /s/ Alfred R. Fabricant
` Alfred R. Fabricant
`
`3
`
`