`
`IN THE UNITED STATES DISTRICT COURT FOR
`THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`CASE NO. 2:17-cv-514-JRG
`(Lead Case)
`
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`JURY TRIAL DEMANDED
`
`CASE NO. 2:17-CV-515-JRG
`(Member Case)
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`JURY TRIAL DEMANDED
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`§§§§§§§§§
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`AGIS SOFTWARE DEVELOPMENT, LLC
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`Plaintiff,
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`v.
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`HTC CORPORATION, et al.
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`Defendant.
`AGIS SOFTWARE DEVELOPMENT, LLC
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`
`
` Plaintiff,
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`
`v.
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`LG ELECTRONICS INC.
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` Defendant.
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`DECLARATION OF MICHAEL A. BERTA IN SUPPORT OF DEFENDANT LG
`ELECTRONICS INC.’S REPLY BRIEF FOR LG’S MOTION FOR SUMMARY
`JUDGMENT OF NON-INFRINGEMENT OF U.S. PATENT NO. 8,213,970
`
`I, Michael A. Berta, state and declare as follows:
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`1.
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`I am a member of Arnold & Porter Kaye Scholer, LLP (“Arnold & Porter”),
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`counsel of record for Defendant LG Electronics Inc. (“LG Korea”). I am a member of the Bar of
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`the State of California and have been admitted to practice in the United States District Court for
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`the Eastern District of Texas (“EDTX”). I provide this declaration in support of Defendant LG
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`Korea’s Reply Brief to its Motion for Summary Judgment of Non-Infringement of U.S. Patent
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`No. 8,213,970. I have personal knowledge of the matters stated in this declaration and would
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`testify competently and truthfully to them if called upon to do so.
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`1
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`Case 2:17-cv-00514-JRG Document 267-1 Filed 03/04/19 Page 2 of 2 PageID #: 21207
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`2.
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`Attached hereto as Exhibit 1 is a true and correct copy of Exhibit A for U.S.
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`Patent No. 8,213,970 against LG Accused Products to Plaintiff’s Disclosure of Asserted Claims
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`and Infringement Contentions, served on LG Electronics Inc. on November 28, 2017.
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`3.
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`Attached hereto as Exhibit 2 is a true and correct copy of Amended Exhibit A for
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`U.S. Patent No. 8,213,970 against LG Accused Products to Plaintiff’s Disclosure of Asserted
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`Claims and Infringement Contentions, served on LG Electronics Inc. on December 19, 2018.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed in San
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`Francisco, California on February 27, 2019.
`
`/s/ Michael A. Berta
`Michael A. Berta
`Attorney for Defendant LG Electronics Inc.
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