`Case 2:17-cv-00517-JRG Document 51-1 Filed 01/19/18 Page 1 Of 2 PageID #: 617
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE EASTERN DISTRICT OF TEXAS
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`MARSHALL DIVISION
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`AGIS Software Development, LLC,
`Plaintiff
`
`v.
`
`
`
`
`
`ZTE Corporation et al.,
`Defendants
`
`
`
`
`
`
`Case No. 2117-CV'517
`
`AFFIDAVIT OF CHAO (GEORGE) SHAN
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`I, Chao (George) Shan, declare under penalty of perjury as follows3
`
`1.
`
`I am over the age of eighteen years and competent to make this declaration.
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`2. The facts stated in this Declaration are true and correct to the best of my
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`knowledge and belief.
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`3.
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`I am employed in the role of Vice President of Human Resources and
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`Administration at ZTE (TX) Inc. (“ZTX”). I have held this position for 3 years
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`and, as such, I have personal knowledge of ZTX’S personnel, operations, and
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`locations worldwide, including the United States.
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`4.
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`I understand that, in the Opposition brief filed by AGIS Software
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`Development, LLC (“AGIS) (dkt. #46), AGIS asserts that “ZTX further
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`concedes that this District (the Eastern District of Texas) is convenient for at
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`least its 14 employees in this District.” However, this misconstrues my
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`earlier declaration (dkt. #38). The fourteen employees living in the Eastern
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`District of Texas are not relevant to this matter, and they are unlikely to
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`testify at all in this case. As I previously declared:
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`
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`Case 2:17-cv-00517-JRG Document 51-1 Filed 01/19/18 Page 2 of 2 PageID #: 618
`Case 2:17-cv-00517-JRG Document 51-1 Filed 01/19/18 Page 2 of 2 PageID #: 618
`
`a. ZTX does not manufacture or make any products in the Eastern
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`District of Texas at all;
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`b. ZTX does not sell or offer to sell any products in the Eastern District of
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`Texas at all;
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`c. ZTX does not import any products in the Eastern District of Texas at
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`all;
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`(1. ZTX does not use any products in the Eastern District of Texas at all;
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`and
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`e. None of ZTX’s employees in Texas are expected to have unique
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`knowledge relevant to this case.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed
`oni
`
`lyiz' ”ff/S
`.r‘
`1,
`
`‘ Date
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`4-:- fi 5;
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`/
`
`By- Cha0( eorge)
`Vice Prseident of Human Resources and Administration, ZTE
`(TX) Inc.
`
`
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