`
`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
`
`§§§§§§§§§
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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 JUSTIN CHI IN SUPPORT OF DEFENDANTS’ JOINT SUR-
`REPLY IN SUPPORT OF THEIR OPPOSITION TO PLAINTIFF’S MOTION TO
`STRIKE PORTIONS OF THE EXPERT REPORT OF MR. SCOTT ANDREWS
`
`I, Justin Chi, state and declare as follows:
`
`1.
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`I am an attorney with the firm of Arnold & Porter Kaye Scholer LLP, counsel of
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`record for Defendant LG Electronics Inc. (“LG Korea”). I am a member of the Bar of the State
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`of Texas 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 Defendants HTC
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`Corporation and LG Korea’s sur-reply in support of their opposition to Plaintiff’s motion to
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`strike portions of the expert report of Mr. Scott Andrews. I have personal knowledge of the
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`matters stated in this declaration and would testify competently and truthfully to them if called
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`upon to do so.
`
`1
`
`
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`Case 2:17-cv-00514-JRG Document 265-1 Filed 03/04/19 Page 2 of 2 PageID #: 21162
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`2.
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`Attached hereto as Exhibit A is a true and correct copy of excerpts of the expert
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`report of Mr. Scott Andrews served on Plaintiff on December 14, 2018.
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`3.
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`Attached hereto as Exhibit B is a true and correct copy of a claim chart attached
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`as Exhibit C-8 to LG Korea’s amended invalidity contentions served on Plaintiff on January 1,
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`2019.
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`4.
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`Attached hereto as Exhibit C is a true and correct copy of a claim chart attached
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`as Exhibit C-8 to HTC Corporation’s invalidity contentions served on Plaintiff on February 6,
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`2018.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed in Palo
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`Alto, California on February 27, 2019.
`
`/s/ Justin Chi
`Justin Chi
`Attorney for Defendant LG Electronics Inc.
`
`2
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`