Case 2:22-cv-00263-JRG-RSP Document 105-1 Filed 08/17/23 Page 1 of 4 PageID #: 7910
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`AGIS SOFTWARE DEVELOPMENT LLC,
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`Plaintiff,
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`v.
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`CIVIL ACTION NO. 2:22-cv-263-JRG
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`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
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`JURY TRIAL DEMANDED
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`Defendant.
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`DECLARATION OF MARK LIANG IN SUPPORT OF SAMSUNG
`ELECTRONICS CO. LTD. AND SAMSUNG ELECTRONICS AMERICA,
`INC.’S RESPONSE TO PLAINTIFF AGIS SOFTWARE DEVELOPMENT
`LLC’S OPPOSED MOTION FOR LEAVE TO FILE SUPPLEMENTAL
`BRIEF REGARDING PLAINTIFF’S OPPOSED MOTION FOR LEAVE
`TO AMEND ITS INFRINGEMENT CONTENTIONS
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`Case 2:22-cv-00263-JRG-RSP Document 105-1 Filed 08/17/23 Page 2 of 4 PageID #: 7911
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`I, Mark Liang, declare and state as follows:
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`1.
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`I am a Partner at O’Melveny & Myers LLP, counsel for Defendants Samsung
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`Electronics Co. Ltd. and Samsung Electronics America, Inc. (“Samsung Electronics”) in the
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`above captioned matter.
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`2.
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`I submit this declaration in support of Samsung Electronics Co. Ltd. and Samsung
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`Electronics America, Inc.’s Response to Plaintiff AGIS Software Development LLC’s Opposed
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`Motion for Leave to File Supplemental Brief Regarding Plaintiff’s Motion for Leave to Amend
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`Its Disclosure of Asserted Claims and Infringement Contentions, filed concurrently herewith. I
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`have personal knowledge of the statements set forth in this declaration and, if called as a witness,
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`would testify competently.
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`3.
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`Attached hereto as Exhibit 19 is a true and correct copy of a written agreement
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`entered between AGIS and Google on July 21, 2023 regarding the production of the June 15,
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`2023 Deposition Transcript of Sorin Dinu from AGIS’s International Trade Commission action,
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`with cited sections highlighted.
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`4.
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`Attached hereto as Exhibit 20 is a true and correct copy of a redacted version of
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`the Declaration of Shannon Shaper, which was filed in support of motions to transfer in in AGIS
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`Software Development LLC v. Waze Mobile Limited, Google LLC, Samsung Electronics Co. Ltd,
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`and Samsung Electronics America, Inc., Nos. 2:19-CV-00359-JRG, 2:19-CV-00361-JRG, 2:19-
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`CV-00362-JRG (E.D. Tex.), with cited sections highlighted. This copy was filed in the Samsung
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`case, 2:19-CV-00362-JRG, as Dkt. 28-18.
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`5.
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`Attached hereto as Exhibit 21 is a true and correct copy of excerpts from AGIS’s
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`2022 complaint against ASUS filed in the Eastern District of Texas (Case No. 2:22-CV-00440-
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`JRG), with cited sections highlighted.
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`6.
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`Attached hereto as Exhibit 22 is a true and correct copy of excerpts from AGIS’s
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`2022 complaint against BLU Products filed in the Eastern District of Texas (Case No. 2:22-CV-
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`00441-JRG), with cited sections highlighted.
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`7.
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`Attached hereto as Exhibit 23 is a true and correct copy of excerpts from AGIS’s
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`Case 2:22-cv-00263-JRG-RSP Document 105-1 Filed 08/17/23 Page 3 of 4 PageID #: 7912
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`2022 complaint against Caterpillar filed in the Eastern District of Texas (Case No. 2:22-CV-
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`00442-JRG), with cited sections highlighted.
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`8.
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`Attached hereto as Exhibit 24 is a true and correct copy of excerpts from AGIS’s
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`2022 complaint against HMD filed in the Eastern District of Texas (Case No. 2:22-CV-00443-
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`JRG), with cited sections highlighted.
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`9.
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`Attached hereto as Exhibit 25 is a true and correct copy of excerpts from AGIS’s
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`2022 complaint against Kyocera filed in the Eastern District of Texas (Case No. 2:22-CV-00444-
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`JRG), with cited sections highlighted.
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`10.
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`Attached hereto as Exhibit 26 is a true and correct copy of excerpts from AGIS’s
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`2022 complaint against Lenovo and Motorola filed in the Eastern District of Texas (Case No.
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`2:22-CV-00445-JRG), with cited sections highlighted.
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`11.
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`Attached hereto as Exhibit 27 is a true and correct copy of excerpts from AGIS’s
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`2022 complaint against OnePlus filed in the Eastern District of Texas (Case No. 2:22-CV-00446-
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`JRG), with cited sections highlighted.
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`12.
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`Attached hereto as Exhibit 28 is a true and correct copy of excerpts from AGIS’s
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`2022 complaint against Panasonic filed in the Eastern District of Texas (Case No. 2:22-CV-
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`00447-JRG), with cited sections highlighted.
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`13.
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`Attached hereto as Exhibit 29 is a true and correct copy of excerpts from AGIS’s
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`2022 complaint against Sony filed in the Eastern District of Texas (Case No. 2:22-CV-00448-
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`JRG), with cited sections highlighted.
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`14.
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`Attached hereto as Exhibit 30 is a true and correct copy of excerpts from AGIS’s
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`2022 complaint against TCL filed in the Eastern District of Texas (Case No. 2:22-CV-00449-
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`JRG), with cited sections highlighted.
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`15.
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`Attached hereto as Exhibit 31 is a true and correct copy of excerpts from AGIS’s
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`2022 complaint against Xiaomi filed in the Eastern District of Texas (Case No. 2:22-CV-00450-
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`JRG), with cited sections highlighted.
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`Case 2:22-cv-00263-JRG-RSP Document 105-1 Filed 08/17/23 Page 4 of 4 PageID #: 7913
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`I declare under penalty of perjury that the foregoing is true and correct. Executed in San
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`Francisco, California on August 17, 2023.
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`Dated: August 17, 2023
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`/s/ Mark Liang
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`Mark Liang
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