`
`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 MICHAEL A. BERTA IN SUPPORT OF LG ELECTRONICS
`INC.’S SUR-REPLY IN OPPOSITION TO AGIS’S DAUBERT MOTION TO EXCLUDE
`THE OPINIONS OF W. CHRISTOPHER BAKEWELL RELATING TO DAMAGES
`
`I, Michael A. Berta, state and declare as follows:
`
`1.
`
`I am a partner of Arnold & Porter Kaye Scholer LLP (“Arnold & Porter”),
`
`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 Sur-Reply In Opposition to AGIS’s Daubert Motion to Exclude the Opinions of W.
`
`Christopher Bakewell Relating to Damages. 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 264-1 Filed 03/04/19 Page 2 of 2 PageID #: 21146
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct highlighted copy of excerpts of
`
`the deposition transcript of W. Christopher Bakewell, taken on February 12, 2019.
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct highlighted copy of the
`
`
`
`
`
`
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed in San
`
`Francisco, California on February 27, 2019.
`
`/s/ Michael A. Berta
`Michael A. Berta
`Attorney for Defendant LG Electronics Inc.
`
`
`
`2
`
`
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