`21028
`
`Exhibit A
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 320-1 Filed 01/14/22 Page 2 of 4 PageID #:
`21029
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`CASE NO. 2:21-cv-00072-JRG
`(Lead Case)
`
`JURY TRIAL DEMANDED
`
`CASE NO. 2:21-cv-00024-JRG
`(Member Case)
`
`JURY TRIAL DEMANDED
`
`§§
`
`§
`§
`§
`
`§§§
`
`§§
`
`§
`§
`§
`§
`
`AGIS SOFTWARE DEVELOPMENT LLC
`
`v.
`
`T-MOBILE USA, INC., and T-MOBILE
`US, INC.
`
`AGIS SOFTWARE DEVELOPMENT LLC
`
`v.
`
`LYFT, INC.
`
`DECLARATION OF BETHANY SALPIETRA IN SUPPORT OF
`LYFT, INC.’S RESPONSE TO PLAINTIFF AGIS SOFTWARE DEVELOPMENT LLC’S
`MOTION FOR RECONSIDERATION AND OBJECTIONS TO THE ORDER
`RECOMMENDING GRANT OF LYFT, INC.’S MOTION TO DISMISS FOR
`IMPROPER VENUE (DKT. 212)
`
`I, Bethany Salpietra, hereby declare as follows:
`
`1.
`
`I am over the age of 21 and am fully competent to make this declaration. I have
`
`personal knowledge of all facts recited herein and state that such facts are true and correct to my
`
`knowledge or information and belief, and, if called upon to do so, I would testify competently
`
`about them.
`
`2.
`
`I am a member in good standing of the State Bar of Texas. I am counsel at the law
`
`firm of Baker Botts L.L.P., 2001 Ross Ave., Ste. 900, Dallas, TX 75201, and I represent Lyft, Inc.
`
`in the above-captioned action. I submit this declaration in support of Lyft’s Response to Plaintiff
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 320-1 Filed 01/14/22 Page 3 of 4 PageID #:
`21030
`
`Agis Software Development LLC’S Motion for Reconsideration and Objections to the Order
`
`Recommending Grant of Lyft, Inc.’s Motion to Dismiss for Improper Venue (Dkt. 212).
`
`3.
`
`Attached hereto as Exhibit 1 is a true and correct copy of selected pages from the
`
`transcript of the Court’s September 29, 2021 hearing on Lyft, Inc.’s Motion to Dismiss for
`
`Improper Venue, dated April 27, 2021.
`
`4.
`
`Attached hereto as Exhibit 2 is a true and correct copy of selected pages from the
`
`transcript of deposition of Max Loosen, dated September 23, 2021.
`
`5.
`
`Attached hereto as Exhibit 3 a true and correct copy of selected pages from the
`
`transcript of deposition of Jeff Tran, dated November 5, 2021.
`
`6.
`
`Attached hereto as Exhibit 4 a true and correct copy of selected pages from the
`
`transcript of deposition of Malcolm K. Beyer, Jr. dated October 20, 2021.
`
`7.
`
`Attached hereto as Exhibit 5 a true and correct copy of selected pages from the
`
`transcript of deposition of David Sietsema, dated November 19, 2021.
`
`8.
`
`Attached hereto as Exhibit 6 is a true and correct copy of Plaintiff’s Initial
`
`Disclosures to Defendant Lyft, Inc. dated June 2, 2021.
`
`9.
`
`Attached hereto as Exhibit 7 is a true and correct copy of selected pages from the
`
`transcript of deposition of Margaret R. T. Beyer, dated October 19, 2021.
`
`10.
`
`Attached hereto as Exhibit 8 a true and correct copy of selected pages from the
`
`transcript of deposition of Ronald Wisneski, dated November 2, 2021.
`
`11. Max Loosen, Lyft’s Regional Director of Operations for Texas and Oklahoma
`
`submitted a declaration and provided sworn testimony in support of Lyft, Inc.’s Motion to Dismiss
`
`for Improper Venue, dated April 27, 2021. Mr. Loosen does not have knowledge pertinent to
`
`AGIS’s claims of patent infringement.
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 320-1 Filed 01/14/22 Page 4 of 4 PageID #:
`21031
`
`I certify under penalty of perjury that the forgoing is true and correct.
`
`Executed on this 12th day of January, 2022 at Dallas, Texas.
`
`Respectfully submitted,
`
`/s/ Bethany Salpietra
`Bethany Salpietra
`
`
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