`
`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
`(CONSOLIDATED 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 LG ELECTRONICS INC.’S
`OPPOSITION TO AGIS SOFTWARE DEVELOPMENT LLC’S MOTIONS IN LIMINE
`
`I, Nicholas H. Lee, state and declare as follows:
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`1.
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`I am a partner of Arnold & Porter Kaye Scholer LLP, counsel of record for
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`Defendant LG Electronics Inc. (“LG Korea”). I am a member of the Bar of the State of
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`California and have been admitted to practice in the United States District Court for the Eastern
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`District of Texas (“EDTX”). I provide this declaration in support of Defendant LG Korea’s
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`Opposition to AGIS Software Development LLC’s (“AGIS”) Motions In Limine. I have
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`personal knowledge of the matters stated in this declaration and would testify competently and
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`truthfully to them if called upon to do so.
`
`1
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`
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`Case 2:17-cv-00514-JRG Document 224-1 Filed 02/21/19 Page 2 of 2 PageID #: 19322
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`2.
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`Attached hereto as Exhibit 1 is a true and correct copy of excerpts of the Expert
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`Report of Edward R. Tittel In Rebuttal To The Expert Report of Joseph McAlexander Regarding
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`Alleged Infringement of U.S. Patent Numbers: 8,213,970; 9,408,055; 9,455,251; and 9,467,838,
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`dated January 11, 2019.
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`3.
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`Attached hereto as Exhibit 2 is a true and correct copy of excerpts of W.
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`Christopher Bakewell’s Rebuttal Expert Report Regarding Damages, dated January 11, 2019.
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`4.
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`Attached hereto as Exhibit 3 is a true and correct copy of excerpts of the Damages
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`Expert Report of Alan Ratliff On Behalf of AGIS With Respect to LG Electronics Inc., dated
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`December 14, 2018.
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`5.
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`Attached hereto as Exhibit 4 is a true and correct copy of excerpts of the Rebuttal
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`Expert Report of Joseph C. McAlexander III Regarding Validity of U.S. Patent Numbers:
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`8,213,970; 9,408,055; 9,445,251; and 9,467,838, dated January 11, 2019.
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`6.
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`Attached hereto as Exhibit 5 is a true and correct copy of the transcript of the
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`deposition of Dr. Neil Siegel, taken on November 14, 2018, in the present action.
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`7.
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`Attached hereto as Exhibit 6 is a true and correct copy of the transcript of the
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`deposition of Dr. Neil Siegel, taken on November 14, 2018, in the case AGIS Software
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`Development LLC v. Apple, Inc., No. 2:17-cv-513-JRG (lead case), No. 2:17-cv-516-JRG.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed in Los
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`Angeles, California on February 19, 2019.
`
`/s/ Nicholas H. Lee
`Nicholas H. Lee
`Attorney for Defendant LG Electronics Inc.
`
`
`
`2
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`