`Case 2:22-cv-00263-JRG-RSP Document 105-2 Filed 08/17/23 Page 1o0f3PagelD#: 7914
`
`EXHIBIT 19
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 105-2 Filed 08/17/23 Page 2 of 3 PageID #: 7915
`Case 2:22-cv-00263-JRG-RSP Document 105-2 Filed 08/17/23 Page 2 of 3 PagelD #: 7915
`
`From:
`To:
`
`Cc:
`Subject:
`Date:
`Attachments:
`
`Evan Langdon
`Trainor, D. Sean; Snyder, Darin; Simmons, Luann L.; Liang, Mark; O"Donnell, Michael; Elizabeth DiMarco;
`Gregory F. Corbett
`
`AGIS; AGIS ITC; Vincent Rubino; Enrique Iturralde; Fred Fabricant
`AGIS and Google Agreement
`Friday, July 21, 2023 3:15:59 PM
`image001.png
`
`[EXTERNAL MESSAGE]
`
`Counsel for Google,
`
`Please confirm by responding to this email that Google agrees to the following:
`Google LLC (“Google”) agrees to produce the unredacted Deposition Transcript of Sorin Dinu, Video,
`and all Exhibits (June 15, 2023) (the “Dinu Transcript”) in the below district court actions and any
`future district court actions involving AGIS Software Development LLC and Advanced Ground
`Information Systems,Inc. (collectively, “AGIS”) and Google’s Find My Device (“FMD”), subject to the
`clarifications below. This includes, but not limited to, producing the Dinu Transcript by July 21, 2023
`in AGIS Software Dev. LLC v. Google LLC, No. 5:22-cv-04826-BLF (N.D. Cal.) (Lead Case) and AGIS
`Software Dev. LLC v. Waze Mobile Limited, No. 5:22-cv-04827-BLF (N.D. Cal.) (Consolidated Case).
`While AGIS objects to Google’s and Samsung’s allegation that there is an open dispute as to whether
`FMD is asserted in AGIS Software Dev. LLC v. SamsungElec. Co., Ltd., No. 2:22-cv-00263-JRG-RSP
`(E.D. Tex.), AGIS agrees to Google’s proposal that the Dinu Transcript will be produced withinfive (5)
`days of resolution of the pending Motion for Leave to Amend Infringement Contentions if the
`Motion forLeave is granted. Without waiving its right to object to the inclusion of FMD as an
`accused productin those cases, Google also agrees to producethe Dinu Transcript in the currently
`stayed district court cases and any future district court actions within five (5) days of being served
`with a subpoena requesting the transcript as part of those cases,listed below, and subject to an
`acceptable protective order being in place in each case:
`
`CONDWUOFBPWNYFP
`
`. AGIS Software Dev. LLC v. Samsung Elec. Co., Ltd., No. 5:22-cv-04825-BLF (N.D. Cal.);
`
`. AGIS Software Dev. LLC v. ASUStek Comput Inc., No. 2:22-cv-00440 (E.D. Tex.);
`
`. AGIS Software Dev. LLC v. BLU Prods., No. 2:22-cv-00441 (E.D. Tex.);
`
`. AGIS Software Dev. LLC v. HMD Global, No. 2:22-cv-00443 (E.D. Tex.);
`
`. AGIS Software Dev. LLC v. Lenovo Grp. Ltd., No. 2:22-cv-00445 (E.D. Tex.);
`
`. AGIS Software Dev. LLC v. Panasonic Corp., No. 2:22-cv-00447 (E.D. Tex.);
`
`. AGIS Software Dev. LLC v. Sony Corp., No. 2:22-cv-00448 (E.D. Tex.); and
`
`. AGIS Software Dev. LLC v. TCL Tech. Grp. Corp., No. 2:22-cv-00449 (E.D. Tex.).
`
`This agreementis not intended to limit and/or remove any pending discovery requests and/or
`discovery obligations with respect to Google or defendants in any case. Google also agreesthat it
`will not argue that there were violations of the ITC Protective Order as alleged in Darin Snyder’s July
`7, 2023 letter to Fred Fabricant, and no further action is needed by either Google or AGIS. AGIS
`agrees to withdraw its pending Motion to Declassify the Deposition Transcript and Certain
`Deposition Exhibits of Mr. Sorin Dinu (Mot. No 1347-017) and nottofile a public version of the
`motion. AGIS and Google agree to include a request for waiver of the requirements of Ground Rule
`1.3.1 and Commission Rule 210.4(f)(7)(ii)(A)(3) to not file a public version.
`
`Regards,
`Evan
`
`| Evan Langdon
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 105-2 Filed 08/17/23 Page 3 of 3 PageID #: 7916
`Case 2:22-cv-00263-JRG-RSP Document 105-2 Filed 08/17/23 Page 3 of 3 PagelD #: 7916
`
`(|
`
`Partner
`elangdon@fabricantllo.com
`T/ 202.507.4899 M/ 703.819.7707
`
`Fabricant LLP
`1101 Pennsylvania Avenue, NW, Suite 300
`Washington, DC 20004
`fabricantllp.com
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
