`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`AGIS Software Development, LLC,
`Plaintiff
`
`v.
`
`ZTE Corporation et al.,
`Defendants
`
`
`Case No. 2:17-cv-517
`
`
`AFFIDAVIT OF TONE HOLMEN
`
`
`I, Tone Holmen, declare under penalty of perjury as follows:
`
`
`1. I am over the age of eighteen years and competent to make this declaration.
`
`2. The facts stated in this Declaration are true and correct to the best of my
`
`knowledge and belief.
`
`3. I am employed in the role of Senior Vice President of Operations with iQor
`
`US Inc. (“iQor”).
`
`4. iQor, not ZTE (USA) Inc. (“ZTA”), operates and controls the call center
`
`located at 6865 Windcrest Drive, Building 1, Plano TX 75024. iQor utilizes
`
`the Plano facility for its operations pursuant to a May 12, 2015 lease with
`
`Legacy VI-VII Investors, LLC.
`
`5. I understand that, in the opposition brief filed by AGIS Software
`
`Development, LLC (“AGIS) (dkt. #46), AGIS asserts, among other things,
`
`that “[ZTA] established a local customer service center with iQor in Plano,
`
`Texas.” I do not know what AGIS means by “establish,” but the Plano call
`
`center is not a ZTA business. ZTA does not have control over the call center
`
`
`
`Case 2:17-cv-00517-JRG Document 51-3 Filed 01/19/18 Page 2 of 3 PageID #: 625
`
`agents’ apparel, nor does ZTA maintain direct control over the call center
`
`agents, representatives, or the call center itself. The call center is an iQor
`
`business. Additionally, iQor entities support numerous Fortune 500
`
`companies in order to provide call center services for their customers; we
`
`employ approximately 10,000 call center agents located in more than fifteen
`
`U.S. cities; we provide initial and periodic training for call center agents; and
`
`we, not these companies, provide supervision over the call center agents.
`
`These call centers are iQor businesses, not the companies’ we provide support
`
`for.
`
` I
`
`
`
`Date
`
`
`
`
`
` declare under penalty of perjury that the foregoing is true and correct. Executed
`on:
`
`
`
`
`
`By: Tone Holmen
` Senior Vice President of Operations, iQor US Inc.
`
`
`
`
`
`Case 2:17-cv-00517-JRG Document 51-3 Filed 01/19/18 Page 3 of 3 PageID #: 626
`
`
`
`
`
`
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