Case 2:17-cv-00514-JRG Document 225-1 Filed 02/21/19 Page 1 of 4 PageID #: 19607
`FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff,
`
`vs.
`
`HTC CORPORATION,
`
`Defendant.
`
`
`DECLARATION OF MIGUEL BOMBACH
`IN SUPPORT OF HTC CORPORATION’S RESPONSES IN OPPOSITION TO
`PLAINTIFF AGIS SOFTWARE DEVELOPMENT, LLC’S MOTIONS IN LIMINE
`
`CASE NO. 2:17-CV-514-JRG
`(LEAD CASE)
`
`JURY TRIAL DEMANDED
`
`FILED UNDER SEAL
`
`
`
`
`FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff,
`
`vs.
`
`HTC CORPORATION,
`
`Defendant.
`
`
`DECLARATION OF MIGUEL BOMBACH
`IN SUPPORT OF HTC CORPORATION’S RESPONSES IN OPPOSITION TO
`PLAINTIFF AGIS SOFTWARE DEVELOPMENT, LLC’S MOTIONS IN LIMINE
`
`CASE NO. 2:17-CV-514-JRG
`(LEAD CASE)
`
`JURY TRIAL DEMANDED
`
`FILED UNDER SEAL
`
`
`
`
`
`Case 2:17-cv-00514-JRG Document 225-1 Filed 02/21/19 Page 2 of 4 PageID #: 19608
`FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER
`
`I, Miguel Bombach, hereby declare as follows:
`
`1.
`
`I am an attorney at the law firm of Perkins Coie LLP and counsel of record for
`
`HTC Corporation (“HTC Corp.”) in the above entitled matter. I am a member of good standing
`
`of the California and United States Patent and Trademark Bar and am admitted to practice in the
`
`Eastern District of Texas.
`
`2.
`
`I make this declaration in support of HTC Corp.’s Opposition to AGIS Software
`
`Development LLC’s Motions in Limine.
`
`3.
`
`Attached hereto as Exhibit 1 is a true and correct copy of excerpts of the Damages
`
`Expert Report of Alan Ratliff, dated December 14, 2018.
`
`4.
`
`Attached hereto as Exhibit 2 is a true and correct copy of excerpts of the Expert
`
`Report of Dr. Andrew Wolfe, dated January 11, 2019.
`
`5.
`
`Attached hereto as Exhibit 3 is a true and correct copy of excerpts of the
`
`deposition transcript of Malcolm Beyer, taken on October 23, 2018.
`
`6.
`
`Attached hereto as Exhibit 4 is a true and correct copy of excerpts of the Rebuttal
`
`Expert Report of Joseph C. McAlexander III Regarding Validity of U.S. Patent Numbers:
`
`8,213,970; 9,408,055; 9,445,251; and 9,467,838, dated January 11, 2019.
`
`7.
`
`Attached hereto as Exhibit 5 is a true and correct copy of excerpts of the
`
`Amendment and Response to Non-Final Office Action under 37 C.F.R. §1.111, dated October
`
`30, 2015 for the application of U.S. Pat. No. 9,408,055.
`
`8.
`
`Attached hereto as Exhibit 6 is a true and correct copy of excerpts of the
`
`Amendment Filed with Request for Continued Examination (RCE) for the application of U.S.
`
`Pat. No. 9,408,055, dated February 26, 2016
`
`1
`
`
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`Case 2:17-cv-00514-JRG Document 225-1 Filed 02/21/19 Page 3 of 4 PageID #: 19609
`FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER
`
`9.
`
`Attached hereto as Exhibit 7 is a true and correct copy of excerpts of the
`
`Amendment and Response to Non-Final Office Action, dated May 31, 2016 for the application
`
`of U.S. Pat. No. 9,408,055.
`
`10.
`
`Attached hereto as Exhibit 8 is a true and correct copy of Plaintiff AGIS Software
`
`Development LLC’s Proposed Witness List for the AGIS Software Development LLC trial.
`
`11.
`
`Attached hereto as Exhibit 9 is a true and correct copy of Advanced Ground
`
`Information Systems, Inc. v. Life360, Inc. Case No. 9:14-cv-80651, Dkt. No. 181 at p. 3, Dkt. No.
`
`181 [Day 1 Trial Transcript]],
`
`12.
`
`Attached hereto as Exhibit 10 is a true and correct copy of excerpts from the
`
`Expert Report of Scott Andrews Regarding Invalidity of U.S. Patent Nos. 8,213,970, 9,408,055,
`
`9,445,251, and 9,467,838.
`
`13.
`
`Attached hereto as Exhibit 11 is a true and correct copy of a letter from Thomas
`
`R. Makin, counsel for Advanced Ground Information Systems, Inc., to Google Inc., dated March
`
`26, 2014.
`
`14.
`
`Attached hereto as Exhibit 12 is a true and correct copy of excerpts of the
`
`deposition transcript of Christopher Russell Rice, dated October 9, 2018.
`
`15.
`
`Attached hereto as Exhibit 13 is a true and correct copy of excerpts of the
`
`deposition transcript of Dr. Neil G. Siegel, taken in the AGIS Software Development LLC v.
`
`Apple, Inc. matter (Case No. 2:17-cv-516-JRG), dated November 14, 2018.
`
`16.
`
`Attached hereto as Exhibit 14 is a true and correct copy of Defendants’ Notice of
`
`Third Party Subpoena to Neil Siegel, dated November 12, 2018.
`
`2
`
`
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`Case 2:17-cv-00514-JRG Document 225-1 Filed 02/21/19 Page 4 of 4 PageID #: 19610
`FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER
`
`17.
`
`Attached hereto as Exhibit 15 is a true and correct copy of excerpts of the
`
`deposition transcript of Dr. Neil G. Siegel, taken in the AGIS Software Development LLC v. HTC
`
`Corporation matter (Case No. 2:17-cv-514-JRG), dated November 14, 2018.
`
`18.
`
`Attached hereto as Exhibit 16 is a true and correct copy of excerpts of Defendants
`
`HTC Corporation’s Invalidity Contentions Pursuant to Local Patent Rules (“P.R.”) 3-3 and 3-4,
`
`dated March 15, 2018.
`
`19.
`
`Attached hereto as Exhibit 17 is a true and correct copy of excerpts of the
`
`Rebuttal Expert Report Regarding Damages of W. Christopher Bakewell, dated January 11,
`
`2019.
`
`20.
`
`Attached hereto as Exhibit 18 is a true and correct copy of excerpts of the
`
`deposition transcript of Alan Ratliff, dated January 24, 2019.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 19th day of February, 2019, in San Diego, California.
`
`/s/ Miguel J. Bombach
`Miguel J. Bombach
`
`3
`
`
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