`10109
`CONFIDENTIAL - FILED UNDER SEAL
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff,
`
`v.
`
`CIVIL ACTION NO. 2:22-cv-263-JRG
`
`
`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
`
`JURY TRIAL DEMANDED
`
`Defendant.
`
`
`DECLARATION OF SHAMBAVI KRISHNAMMURTHI
`
`
`
`I, Shambavi Krishnammurthi, hereby declare as follows:
`
`1.
`
`I am a Product Manager at Google LLC (“Google”). I have been a Google
`
`employee since 2020. I live and work in the San Francisco Bay Area. I am over 18 years of age
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`and have personal knowledge of the facts set forth in this Declaration. If called as a witness, I
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`could and would testify competently to the information contained herein.
`
`2.
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`I am a product manager for Find My Device (“FMD”) and have been in that role
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`since November 2021. In this role, I regularly work with and communicate with other team
`
`members responsible for FMD and provide overall product development and strategy. Members
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`of the FMD team are based in the San Francisco Bay Area, London, United Kingdom, and Tel
`
`Aviv, Israel. Based on my discussions with the individuals identified in paragraph 3 below and
`
`my experience with the FMD team, no members of the team are based in Texas.
`
`3.
`
`Based on my discussions with the below individuals and my experience with the
`
`FMD team, I have identified the following Google employees with knowledge of FMD:
`
`1
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 123-3 Filed 09/07/23 Page 2 of 3 PageID #:
`10110
`CONFIDENTIAL - FILED UNDER SEAL
`
`a. Ronald Ho is a Group Product Manager at Google for teams working on multi-device
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`products, since November 2021. In that role, Mr. Ho oversaw product development and
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`strategy for FMD from November 2021 through July 2023. Mr. Ho is based in the San
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`Francisco Bay Area.
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`b. Jonathan Brunsman is a Distinguished Engineer at Google who worked on FMD until and
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`including 2020. Mr. Brunsman was based in the San Francisco Bay Area during the time he
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`worked on FMD. Since April 2022, he has been based in Boulder, Colorado.
`
`c. William Luh is a Software Engineer Manager at Google who worked on FMD until and
`
`including 2019. Mr. Luh is based in the San Francisco Bay Area.
`
`d. Sorin Dinu is a Software Engineer at Google responsible for the development and
`
`maintenance of FMD. Mr. Dinu is based in London, United Kingdom. Mr. Dinu is part of a
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`London-based team that works on FMD. The team currently
`
`technical aspects of FMD transitioned from engineers based in the San Francisco Bay Area
`
` Responsibilities for certain
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`to the London-based team starting in the second quarter of 2019.
`
`
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`2
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`
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`Case 2:22-cv-00263-JRG-RSP Document 123-3 Filed 09/07/23 Page 3 of 3 PageID #:
`10111
`TIAL - FILED
`
`ID
`
`0
`
`e. Da id Lazaro i a oftwar
`
`ng1n r at Googl
`
`h
`
`i part fan n 1n rm t am
`
`in Tel
`
`I rael that ha been
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`ter o n1ber 0 1 Mr. azar v and th r
`
`t
`
`th t
`
`1n
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`l
`
`i b gan taking nm re engine ring responsibiliti with r
`
`This work
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`tart din O 1
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`in th
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`an Francisco Bay Area be£ r
`
`1n
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`tr
`
`iti n d
`
`th I r 1-b
`
`d t a1n.
`
`n
`
`fth
`
`I rael team s work ha chan
`
`th un
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`4.
`
`A a n1att r o
`
`u nt in
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`products and
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`rv1c
`
`ar norm 11
`
`m int in d b th mpl y w rking n th
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`products and
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`r 1c
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`. I follo
`
`that pra ti
`
`and h indi iduals identifi d ab v d
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`w 11.
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`According! docum nt r garding th r earc~ design, and developm nt M w uld
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`primaril er at d and maintain d in the an Francisco Bay Area
`
`nd n nd I ra 1.
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`I d clar und r th
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`la
`
`of th
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`nited
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`tate of Am rica that th
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`r g 1ng
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`t u
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`corr ct. x cut din an ranci co
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`alifornia on ugust 31 2023.
`
`bamba i Kri hnammurthi
`
`3
`
`
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