`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`EXHIBIT A
`
`EXHIBIT A
`
`
`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Attachments:
`
`
`
`Rubino, Vincent J. <VRubino@brownrudnick.com>
`Tuesday, February 6, 2018 6:22 PM
`Lavenue, Lionel; AGIS-Lit
`Schulz, Bradford; sbaxter@mckoolsmith.com; Jennifer Truelove
`(jtruelove@McKoolSmith.com)
`RE: AGIS Software Development, LLC v. HTC Corporation, Case No. 2:17-cv-00514-JRG
`(Lead Case) AGIS Software Development, LLC v. ZTE Corporation, et al., Case No. 2:17-
`cv-00517-JRG (Consolidated Case)
`Exhibit B - 2018-02-06 Corrected Brief (Redline).pdf; Exhibit C - 2018-02-06 Corrected
`Declaration to ZTE.PDF; Exhibit D - Corrected Exhibit 11.pdf; 2018-02-06 - [Proposed]
`Order Grtg AGIS Mtn to File Corrected Sur-Reply to ZTE Mtn to Dismiss_Transf.DOCX;
`2018-02-06 - AGIS Mtn to File Corrected Sur-Reply to ZTE Mtn to Dismiss_Transfer
`(Dkt. 38).DOCX; 2018-02-06 - Declaration of V. Rubino ISO Motion for Leave to Correct
`Sur-Reply ZTE.docx.pdf; Exhibit A - 2018-02-06 Corrected Brief (clean).pdf
`
`Lionel,
`
`
`Attached is our draft motion and exhibits. We would like to get this on file tonight.
`
`
`Best,
`Vincent
`
`
`
`
`
`Vincent Rubino
`
`
`Brown Rudnick LLP
`Seven Times Square
`New York, NY 10036
`T: 212-209-4974
`F: 212-938-2974
`vrubino@brownrudnick.com
`www.brownrudnick.com
`Please consider the environment before printing this e-mail
`
`
`
`
`From: Lavenue, Lionel [mailto:lionel.lavenue@finnegan.com]
`Sent: Monday, February 05, 2018 7:58 PM
`To: Rubino, Vincent J.; AGIS-Lit
`Cc: Schulz, Bradford; sbaxter@mckoolsmith.com; Jennifer Truelove (jtruelove@McKoolSmith.com)
`Subject: RE: AGIS Software Development, LLC v. HTC Corporation, Case No. 2:17-cv-00514-JRG (Lead Case)
`AGIS Software Development, LLC v. ZTE Corporation, et al., Case No. 2:17-cv-00517-JRG (Consolidated Case)
`
`
`External E-mail. Use caution accessing links or attachments.
`
`Vincent –
`
`I just landed (was in the air). I see the attachments, but have you sent us the proposed motion to which you
`seek non‐opposition?
`
`
`1
`
`
`
`We are likely not to oppose, and we’ll separately notify the Court that AGIS refused to correct a material error in
`its sur‐reply brief.
`
`
`Thanks,
`
`
`Lionel
`
`
`From: Rubino, Vincent J. [mailto:VRubino@brownrudnick.com]
`Sent: Monday, February 5, 2018 6:14 PM
`To: Lavenue, Lionel <lionel.lavenue@finnegan.com>; AGIS‐Lit <agislit@brownrudnick.com>
`Cc: Schulz, Bradford <Bradford.Schulz@finnegan.com>; sbaxter@mckoolsmith.com; Jennifer Truelove
`(jtruelove@McKoolSmith.com) <jtruelove@McKoolSmith.com>
`Subject: RE: AGIS Software Development, LLC v. HTC Corporation, Case No. 2:17‐cv‐00514‐JRG (Lead Case) AGIS
`Software Development, LLC v. ZTE Corporation, et al., Case No. 2:17‐cv‐00517‐JRG (Consolidated Case)
`
`
`
`
`Lionel,
`
`
`We have been on the line for 15 minutes. As it appears that this time is no longer good for you, please let us
`know as soon as possible whether ZTE will oppose AGIS's motion to correct. If ZTE will oppose, please let us
`know your earliest availability to confer. We are generally available later tonight EST or tomorrow afternoon
`EST.
`
`
`Regards,
`Vincent
`
`
`
`
`
`Vincent Rubino
`
`
`Brown Rudnick LLP
`Seven Times Square
`New York, NY 10036
`T: 212-209-4974
`F: 212-938-2974
`vrubino@brownrudnick.com
`www.brownrudnick.com
`Please consider the environment before printing this e-mail
`
`
`
`
`From: Rubino, Vincent J.
`Sent: Monday, February 05, 2018 4:40 PM
`To: 'Lavenue, Lionel'; AGIS-Lit
`Cc: Schulz, Bradford; sbaxter@mckoolsmith.com; Jennifer Truelove (jtruelove@McKoolSmith.com)
`Subject: RE: AGIS Software Development, LLC v. HTC Corporation, Case No. 2:17-cv-00514-JRG (Lead
`Case) AGIS Software Development, LLC v. ZTE Corporation, et al., Case No. 2:17-cv-00517-JRG
`(Consolidated Case)
`
`
`Lionel,
`
`
`Attached are AGIS's proposed corrected sur‐reply, declaration, and Exhibit 11, which reflect a correction
`of the clerical error in AGIS's briefing regarding the attachment of the incorrect document as Exhibit 11.
`
`
`2
`
`
`
`Again, the clerical error (corrected in the attached) is completely unrelated to the issue of whether ZTE
`contested in its briefing that ZTA commits the alleged acts of infringement in this district. ZTE has no
`good faith basis to withhold consent to correct the clerical error. We do not agree that there is any
`need for AGIS to revise its briefing with respect to the 1400(b) issue, and we do not agree that ZTE has
`any basis to request additional briefing on the issue.
`
`
`Please let us know whether ZTE opposes AGIS's correction. If ZTE opposes, we are available to confer at
`6PM eastern tonight. We can use the following dial‐in:
`Dial‐in: 877‐211‐3621
`Passcode: 145074
`
`
`Regards,
`Vincent
`
`
`
`
`
`Vincent Rubino
`
`
`Brown Rudnick LLP
`Seven Times Square
`New York, NY 10036
`T: 212-209-4974
`F: 212-938-2974
`vrubino@brownrudnick.com
`www.brownrudnick.com
`Please consider the environment before printing this e-mail
`
`
`
`
`
`
`From: Lavenue, Lionel [mailto:lionel.lavenue@finnegan.com]
`Sent: Friday, February 02, 2018 12:11 PM
`To: Rubino, Vincent J.; AGIS-Lit
`Cc: Schulz, Bradford; sbaxter@mckoolsmith.com; Jennifer Truelove
`(jtruelove@McKoolSmith.com)
`Subject: RE: AGIS Software Development, LLC v. HTC Corporation, Case No. 2:17-cv-00514-JRG
`(Lead Case) AGIS Software Development, LLC v. ZTE Corporation, et al., Case No. 2:17-cv-
`00517-JRG (Consolidated Case)
`
`
`Vincent,
`
`
`You refer to “deficiencies in … existing briefing,” but the only deficiencies are in AGIS’s sur‐reply
`briefing.
`
`
`The simple truth is that AGIS made two misrepresentations of fact in its sur‐reply, which was
`filed on Friday, January 26, 2018, and on Monday, January 29, 2018, Defendants ZTA and ZTX
`promptly notified AGIS of the two errors. Now, AGIS wishes to correct only one error.
`
`It is improper for AGIS correct one error (incorporating AGIS’s erroneous attorney declaration),
`while allowing the other error (AGIS’s misrepresentation of Defendants’ 1400(b)
`argument). Defendants ZTA and ZTX are not withholding consent as leverage, but to contrary,
`Defendants ZTA and ZTX are attempting to ensure that proper corrections of misrepresentation
`of fact in the AGIS sur‐reply are made.
`
`
` With respect to AGIS’s first misrepresentation of fact, if AGIS still wishes to correct its
`sur‐reply brief, then Defendants ZTA and ZTX request that AGIS inform us of the
`3
`
`
`
`proposed corrections, so that we may take a position on the potential motion for
`correction. Defendants can only agree to AGIS’s corrections, once we see the
`anticipated corrections.
`
` With respect to AGIS’s second misrepresentation of fact, it is undisputed from your
`emails that AGIS misrepresented the “acts of infringement” issue in the sur‐reply, and
`we note that a simple correction would moot the issue. The current sur‐reply brief is
`clearly in error, in stating that “Defendants did not argue in its Motion to Dismiss that
`the ‘acts of infringement’ requirement of 1400(b) was not satisfied as to ZTA. Dkt. 38 at
`15‐20.” For example, as we already indicated, Defendants clearly noted in the opening
`brief that, “no Defendant resides, has committed alleged acts of infringement, or has a
`regular and established place of business in this District.” (Dkt. No. 38 at 1, emphasis
`added). For example, a correct sur‐reply statement would be, “Defendants did not
`argue in its Motion to Dismiss argument section that the ‘acts of infringement’
`requirement of 1400(b) was not satisfied as to ZTA. Dkt. 38 at 15‐20.” But, it is just a
`plan misrepresentation of fact for AGIS to state otherwise.
`
`o We further note that the sur‐reply brief was the first time that AGIS asserted this
`misrepresentation of “fact.” AGIS’s opposition brief had only referenced the
`Amended Complaint, not the 1400(b) requirement. See Dkt. 46 at 15 (“ZTA does
`not dispute that it has engaged in infringing activities in this District as alleged in
`the Amended Complaint and, thus, concedes that ZTA engaged, and continues
`to engage, in the infringing activities alleged in the Amended Complaint. Dkt. 32
`at 23‐83.”). And, in the reply brief, Defendants ZTA and ZTX responded to that
`argument regarding the Amended Complaint. See Dkt. 51 at 4 (“ZTA also denies
`any acts of infringement.”); see also id. (“AGIS incorrectly alleges that ‘ZTA does
`not dispute’ infringement‐‐‐even that it ‘concedes that ZTA . . . engage[s] in the
`infringing activities. This conclusory rhetoric is baseless, at least as Defendants
`have yet to answer the Amended Complaint, given the pending motion to
`dismiss and/or to transfer”). In the opposition brief, AGIS did not assert that
`ZTA waived the “acts of infringement” requirement of 1400(b), until AGIS made
`that argument for the first time in its sur‐reply brief. See Dkt. 52 at 2
`(“Defendants did not argue in its Motion to Dismiss that the ‘acts of
`infringement’ requirement of 1400(b) was not satisfied as to ZTA. Dkt. 38 at 15‐
`20.”) The local EDTX rules do not permit the presentation of new facts in reply
`and sur‐reply briefs. As such, not only is AGIS’s allegation that ZTA did not argue
`the acts of infringement requirement of 1400(b) unambiguously in error, but it
`is further improper as a new allegation, only first alleged by AGIS in its sur‐reply
`brief. See Gillaspy v. Dallas Ind. School Dist., 278 Fed. Appx. 307, 315 (5th Cir.
`2008) (“It is the practice of [the 5th Cir.] to refuse to consider arguments raised
`for the first time in reply [and sur‐reply] briefs”). Therefore, if AGIS continues to
`refuse to correct their misrepresentation, then Defendants will request an
`opportunity to respond to any AGIS motion to correct. Your allegation that
`Defendants ZTA and ZTX are “withholding consent to correct the clerical error in
`the declaration as leverage” is plainly incorrect, as Defendants ZTA and ZTX is
`merely going to insist on addressing the errors by AGIS, in one manner or
`another. If we do resolve the issue in your motion for correction, then we will
`address the error in another manner. But, for now, we are attempting to work
`with you in good faith to address the clear error by AGIS.
`
`
`
`
`
`
`
`4
`
`
`
`But, for now, as a next step, we suggest that you provide us with the intended corrections that
`AGIS wishes to make to its sur‐reply brief. Once we review those corrections, we will be in a
`best position to take a position on the potential motion for correction.
`
`
`As for a meet‐and‐confer, as I noted yesterday, I am generally available between 10am‐3pm
`Eastern or after 6pm Eastern, or on Monday. But, it would be helpful for the meet‐and‐confer
`to see whatever corrections that AGIS wishes to make to its sur‐reply brief for us to take a
`position.
`
`
`Regards,
`
`
`Lionel
`
`
`From: Rubino, Vincent J. [mailto:VRubino@brownrudnick.com]
`Sent: Thursday, February 1, 2018 2:50 PM
`To: Lavenue, Lionel <lionel.lavenue@finnegan.com>; AGIS‐Lit <agislit@brownrudnick.com>
`Cc: Schulz, Bradford <Bradford.Schulz@finnegan.com>; sbaxter@mckoolsmith.com; Jennifer
`Truelove (jtruelove@McKoolSmith.com) <jtruelove@McKoolSmith.com>
`Subject: RE: AGIS Software Development, LLC v. HTC Corporation, Case No. 2:17‐cv‐00514‐JRG
`(Lead Case) AGIS Software Development, LLC v. ZTE Corporation, et al., Case No. 2:17‐cv‐00517‐
`JRG (Consolidated Case)
`
`
`
`
`Lionel,
`
`It is obvious that you are withholding consent to correct the clerical error in the declaration as
`leverage to extract our consent to give ZTE another brief to address deficiencies in its existing
`briefing. As the clerical error is completely unrelated to the issue of whether ZTE contested in
`its briefing that ZTA commits the alleged acts of infringement in this district, ZTE has no good
`faith basis to withhold consent to correct the clerical error.
`
`
`Again, we do not agree that there is any need for AGIS to revise its briefing with respect to the
`1400(b) issue, and we do not agree that ZTE has any basis to request additional briefing on the
`issue.
`
`
`We are available to meet and confer on these issues on Friday. Please advise as to your
`availability.
`
`
`Regards,
`Vincent
`
`
`
`
`
`Vincent Rubino
`
`
`Brown Rudnick LLP
`Seven Times Square
`New York, NY 10036
`T: 212-209-4974
`F: 212-938-2974
`vrubino@brownrudnick.com
`www.brownrudnick.com
`Please consider the environment before printing this e-mail
`5
`
`
`
`
`
`
`
`
`
`From: Lavenue, Lionel [mailto:lionel.lavenue@finnegan.com]
`Sent: Wednesday, January 31, 2018 9:31 PM
`To: Rubino, Vincent J.; AGIS-Lit
`Cc: Schulz, Bradford; sbaxter@mckoolsmith.com; Jennifer Truelove
`(jtruelove@McKoolSmith.com)
`Subject: RE: AGIS Software Development, LLC v. HTC Corporation, Case No. 2:17-cv-
`00514-JRG (Lead Case) AGIS Software Development, LLC v. ZTE Corporation, et al.,
`Case No. 2:17-cv-00517-JRG (Consolidated Case)
`
`
`Vincent,
`
`It seems clear that AGIS made two clear and unambiguous errors in its sur‐reply.
`
`
`Now, AGIS seeks to correct only one of those errors, that is, the one incorporating the
`erroneous attorney declaration, but AGIS does not wish to correct the other error. If so,
`this would be inappropriate, as AGIS should correct both errors. If AGIS will not agree to
`correct both errors, then Defendants ZTA and ZTX will oppose a motion to correct only
`one of the two errors, unless both errors are corrected.
`
`
`First, in the sur‐reply, AGIS incorrectly alleges they informed Defendants of the L.P.R. 3‐
`1 Infringement Contention contents. This error is duplicated three‐fold, in the sur‐reply
`brief, the Exhibit, and the attorney declaration.
`
`
` AGIS incorrectly states that “[o]n November 28, 2018, Plaintiff informed
`Defendants that its infringement contentions rely solely on public documents,
`including source code excerpts.” (Dkt. No. 52, p. 8).
` AGIS incorrectly filed Ex. 11 infringement contentions for AGIS Software
`Development LLC v. Huawei et al., No. 2:17‐cv‐513‐JRG.
` AGIS’s counsel‐‐‐Vincent J. Rubino III‐‐‐after “being duly sworn” and declaring
`“under penalty of perjury that the foregoing is true and correct,” falsely stated
`that “[a]ttached hereto as Exhibit 11 is a true and correct copy of the cover
`document of Plaintiff’s Disclosure of Asserted Claims and Infringement
`Contentions, dated November 28, 2017.”
`
`
`
`Second, AGIS incorrectly alleges Defendants did not argue the ‘acts of infringement’
`requirement of 1400(b). This erroneous accusation is baseless. AGIS states that
`“Defendants did not argue in its Motion to Dismiss that the ‘acts of infringement’
`requirement of 1400(b) was not satisfied as to ZTA.” Dkt. 38 at 15‐20.”
`
`
` However, this statement and citation are incorrect, as Defendants’ Motion to
`Dismiss clearly states, “no Defendant resides, has committed alleged acts of
`infringement, or has a regular and established place of business in this District.”
`(Dkt. No. 38 at 1, emphasis added).
` Additionally, pursuant to Local Rule 7(a)(1), Defendants stated that the Court
`must decide the issue of venue because “the Defendants do not reside in this
`Judicial District, have not committed alleged acts of infringement in this
`District, and do not have a regular and established place of business
`here.” (Dkt. No. 38, emphasis added).
`
`
`
`6
`
`
`
`As evident by the opening brief, Defendants did not waive any argument that they do
`not infringe, and Defendants did not concede that ZTA or any ZTE Defendant engaged,
`and/or continues to engage, in any of the infringing activities alleged in the Amended
`Complaint. Also, AGIS did not inform Defendants of their infringement contentions until
`January 19, 2018, which was hours after Defendants’ reply filing, a month after AGIS’s
`venue motion response, and nearly two months after AGIS’s alleged sur‐reply date.
`
`
`Therefore, again, if AGIS does not agree to correct both clear and unambiguous errors,
`based on specifically erroneous statements in its briefing, then ZTA and ZTX will oppose
`any attempt by AGIS to file a motion to correct only one error (by unopposed motion to
`correct).
`
`
`As a compromise, however, if AGIS agrees that the ZTE Defendants may respond to any
`“motion to correct the sur‐reply brief and associated declaration,” as filed by AGIS, then
`ZTE would not oppose such a motion, with the understand that any motion for leave by
`AGIS would specifically include our agreement that the ZTE Defendants would have an
`opportunity to respond the any motion to correct (such response to the limited to the
`two errors).
`
`If you are in the courtroom tomorrow in the EDTX, I can meet‐and‐confer after the
`conference, if still needed in view of this email; if not, I am generally available on Friday,
`February 2, 2018, between 10am‐3pm Eastern or after 6pm Eastern.
`
`
`Regards,
`
`
`Lionel
`
`
`From: Rubino, Vincent J. [mailto:VRubino@brownrudnick.com]
`Sent: Wednesday, January 31, 2018 2:49 PM
`To: Lavenue, Lionel <lionel.lavenue@finnegan.com>; AGIS‐Lit
`<agislit@brownrudnick.com>
`Cc: Schulz, Bradford <Bradford.Schulz@finnegan.com>; sbaxter@mckoolsmith.com;
`Jennifer Truelove (jtruelove@McKoolSmith.com) <jtruelove@McKoolSmith.com>
`Subject: RE: AGIS Software Development, LLC v. HTC Corporation, Case No. 2:17‐cv‐
`00514‐JRG (Lead Case) AGIS Software Development, LLC v. ZTE Corporation, et al., Case
`No. 2:17‐cv‐00517‐JRG (Consolidated Case)
`
`
`
`
`Lionel,
`
`It appears that you have identified two distinct issues, each of which I address in turn.
`
`
`First, thank you for pointing out the clerical error with regard to the date and
`corresponding exhibit 11. AGIS plans to file a motion to correct the sur‐reply brief and
`associated declaration.
`
`
`Second, we disagree with your characterizations of our sur‐reply brief and we do not
`intend to file any clarification on the points you identify other than to change the date
`as set forth above.
`
`
`7
`
`
`
`Please let us know your availability to meet and confer. We are available to confer on
`these issues on Thursday at 1pm eastern.
`
`
`Regards,
`Vincent
`
`
`
`
`
`Vincent Rubino
`
`
`Brown Rudnick LLP
`Seven Times Square
`New York, NY 10036
`T: 212-209-4974
`F: 212-938-2974
`vrubino@brownrudnick.com
`www.brownrudnick.com
`Please consider the environment before printing this e-mail
`
`
`
`
`From: Lavenue, Lionel [mailto:lionel.lavenue@finnegan.com]
`Sent: Monday, January 29, 2018 7:00 PM
`To: Dangelmajer, Susan E.; AGIS-Lit; Rubino, Vincent J.
`Cc: Schulz, Bradford
`Subject: RE: AGIS Software Development, LLC v. HTC Corporation, Case No.
`2:17-cv-00514-JRG (Lead Case) AGIS Software Development, LLC v. ZTE
`Corporation, et al., Case No. 2:17-cv-00517-JRG (Consolidated Case)
`
`
`Counsel for AGIS,
`
`
`We note several significant errors in AGIS’s sur‐reply, as filed on January 26,
`2018.
`
`
`Defendants ask that AGIS withdraw these positions and refile its sur‐reply, or we
`will seek for leave to respond to the errors.
`
`
`First, AGIS alleges that, “[o]n November 28, 2018, Plaintiff informed [the ZTE]
`Defendants that its infringement contentions rely solely on public documents,
`including source code excerpts.” (D.E. No. 52, pg. 8).
`
`
` This allegation, along with the citation to Ex. 11 and Vincent Rubino’s
`declaration (as declared by him to be truthful), are all made in
`error. AGIS did not inform the ZTE Defendants of any infringement
`contentions on November 28, 2017. In fact, AGIS did not serve any
`infringement contentions on the ZTE Defendants until after Defendants
`filed their reply brief, on January 19, 2018 (compare Defendants’ filing
`time vs. AGIS’s email time on January 19, 2018).
` Instead, note that Ex. 11 and Vincent Rubino’s declaration reference
`infringement contentions served on Huawei, not on the ZTE
`Defendants. Vincent Rubino’s declaration is thus patently incorrect in
`that it states “Exhibit 11 is a true and correct copy of the cover
`document of Plaintiff’s Disclosure of Asserted Claims and Infringement
`Contentions.” (Emphasis added). Thus, unfortunately, Exhibit 11 is not
`a true and correct copy of AGIS’s infringement contentions on the ZTE
`Defendants, because it is in fact the contentions served to a different
`
`8
`
`
`
`entity in an entirely different case (the Huawei Defendants, in the
`Huawei case).
`
`
`
`These errors, duplicated three times in the sur‐reply itself, in Ex. 11, and by AGIS
`attorney Vincent Rubino’s declaration are entirely false and need to be
`corrected.
`
`
`Second, AGIS continues to allege that “Defendants did not argue in its Motion to
`Dismiss that the ‘acts of infringement’ requirement of 1400(b) was not satisfied
`as to ZTA,” and that “ZTA has, therefore, waived this argument, and its attempt
`to resurrect it in its Reply fails.” (D.E. No. 52, pg. 2).
`
`
` Again, this allegation is erroneous. In the opening brief, “Defendants
`ZTE (TX) Inc. and ZTE (USA) Inc.” moved to dismiss AGIS’s complaint for
`improper venue. The brief clearly states that “no Defendant resides,
`has committed alleged acts of infringement, or has a regular and
`established place of business in this District.” (D.E. No. 38, pg. 1,
`Emphasis added).
` Additionally, pursuant to Local Rule 7(a)(1), Defendants stated that the
`Court must decide the issue of venue because “the Defendants do not
`reside in this Judicial District, have not committed alleged acts of
`infringement in this District, and do not have a regular and established
`place of business here.” (D.E. No. 38, Emphasis added).
` Also, per the very authority that you quote in your opposition brief,
`“the issue of infringement is not reached on the merits in considering
`venue requirements.” In re Cordis Corp., 769 F.2d 733, 737 (Fed. Cir.
`1985).
` Thus, despite these clear recitations in the opening brief, the reiterated
`denial in the reply brief, and your acknowledgment that substantive
`infringement issues cannot be decided on a motion to dismiss for
`improper venue (not to mention that the burden is yours to provide),
`AGIS continuous to erroneously litigate this irrelevant issue with
`baseless conclusory statements, as compounded by the errors Ex. 11
`and Vincent Rubino’s declaration.
`
`
`
`These clearly erroneous arguments by AGIS are highlighted by the multiple
`errors as to the citation to Ex. 11 and Vincent Rubino’s declaration. Indeed, as
`evident by the opening brief, Defendants did not waive any argument that they
`do not infringe, and Defendants did not concede that ZTA or any ZTE Defendant
`engaged, and/or continues to engage, in any of the infringing activities alleged
`in the Amended Complaint. AGIS also needs to remedy this erroneous
`allegation.
`
`
`Please confirm by February 1, 2018 whether AGIS will remedy these errors by
`refiling its sur‐reply and removing these allegations. If not, Defendants will seek
`leave to respond to these errors.
`
`
`Regards,
`
`
`Lionel
`
`
`9
`
`
`
`From: Dangelmajer, Susan E. [mailto:SDangelmajer@brownrudnick.com]
`Sent: Friday, January 19, 2018 6:34 PM
`To: Lavenue, Lionel <lionel.lavenue@finnegan.com>
`Cc: AGIS‐Lit <agislit@brownrudnick.com>; Rubino, Vincent J.
`<VRubino@brownrudnick.com>
`Subject: AGIS Software Development, LLC v. HTC Corporation, Case No. 2:17‐cv‐
`00514‐JRG (Lead Case) AGIS Software Development, LLC v. ZTE Corporation, et
`al., Case No. 2:17‐cv‐00517‐JRG (Consolidated Case)
`
`
`
`
`Lionel,
`
`
`Attached please find AGIS Software Development, LLC's letter regarding todays
`document productions.
`
`
`Regards,
`
`
`
`
`
`
`Susan E. Dangelmajer
`Paralegal
`
`Brown Rudnick LLP
`Seven Times Square
`New York, NY 10036
`T: 212-209-4845
`F: 212-938-2845
`M: 732-668-4922
`sdangelmajer@brownrudnick.com
`www.brownrudnick.com
`
`Recipient of "European Venture Capital Service
`Provider of the Year" Award from Investor AllStars
`
`Named "Top Legal Advisor to the US Hedge
`Fund Community" by The Hedge Fund Journal
`
`Please consider the environment before printing this e-mail
`
`
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`11
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