`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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` Plaintiff,
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`v.
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`AGIS Software Development, LLC,
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`ZTE CORPORATION AND
`ZTE (TX), INC.,
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`
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`______________________________________
`
` Defendants
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`.
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`Case No. 2:17-CV-00517-JRG
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`DECLARATION OF LIONEL LAVENUE IN SUPPORT OF DEFENDANT ZTE (TX),
`INC.’S MOTION TO DISMISS PLAINTIFF’S COMPLAINT FOR FAILURE TO STATE
`A CLAIM AND IMPROPER VENUE OR IN THE ALTERNATIVE TO TRANSFER
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`I, Lionel Lavenue, declare and testify as follows:
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`1.
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`2.
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`3.
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`4.
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`I am an attorney with the law firm Finnegan, Henderson, Farabow, Garrett, & Dunner,
`LLP, counsel of record for Defendant ZTE (TX), INC. I am knowledgeable about the
`facts set forth in this declaration and could and would testify competently to them if
`called as a witness, unless otherwise stated.
`
`Attached as Exhibit A is a true and correct copy of a webpage located at
`https://mycpa.cpa.state.tx.us/coa/coaSearch.do. The webpage includes “Franchise Tax
`Account Status” and a “Public Information Report” for “Agis Software Development
`LLC.”
`
`Attached as Exhibit B is a true and correct copy of webpages located at
`https://www.google.com/maps/. The webpages include directions and distances from the
`corporate headquarters complex of Google, Inc.in Mountain View California to the Sam
`B. Hall Jr. Federal Building in Marshall Texas and to the Robert F. Peckham Federal
`Building in San Jose.
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`Attached as Exhibit C is a true and correct copy of a portion of a Lex Machina Custom
`Report for Northern District of California and Eastern District of Texas Patent Cases
`Filed 2016 to June 2017.
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`Case 2:17-cv-00517-JRG Document 28-2 Filed 09/26/17 Page 2 of 2 PageID #: 212
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`Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the foregoing is true and
`correct.
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`Executed on September 26, 2017.
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`/s/ Lionel M. Lavenue
`Lionel M. Lavenue, Esq.
`lionel.lavenue@finnegan.com
`FINNEGAN, HENDERSON, FARABOW,
`GARRETT & DUNNER, LLP
`Two Freedom Square
`11955 Freedom Drive
`Reston, VA 20190-5675
`Tel: (571) 203-2700
`Fax: (202) 408-4400
`
`ATTORNEY FOR DEFENDANT
`ZTE (TX), INC.
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`