`10112
`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
`(LEAD CASE)
`
`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
`
`JURY TRIAL DEMANDED
`
`Defendant.
`
`
`
`DECLARATION OF BYEONG CHUL NAM IN
`SUPPORT OF SAMSUNG’S MOTION TO TRANSFER VENUE
`
`
`
`I, Byeong Chul Nam, hereby declare as follows:
`
`1.
`
`I am over 18 years of age and competent to make this declaration. If called to
`
`testify as a witness in this matter, I could and would testify truthfully to each of the statements in
`
`this declaration.
`
`2.
`
`I am employed as a Principal Engineer at Samsung Electronics Co., Ltd. (“SEC”)
`
`in Gumi-si, Republic of Korea. I have been employed by SEC since 2006.
`
`3.
`
`I understand that AGIS Software Development LLC (“AGIS”) filed on July 14,
`
`2022, the above captioned patent infringement lawsuit against Samsung Electronics Co., Ltd.
`
`(“SEC”) and Samsung Electronics America, Inc. (“SEA”) (collectively, “Samsung”) in the
`
`United States District Court for the Eastern District of Texas (“EDTX”). I provide this
`
`declaration in support of Samsung’s Motion to Sever Claims Related to Find My Device and
`
`Transfer Them to the Northern District of California (“NDCA”). Unless otherwise indicated
`
`1
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 123-4 Filed 09/07/23 Page 2 of 3 PageID #:
`10113
`CONFIDENTIAL - FILED UNDER SEAL
`
`below, the statements in this declaration are based on my personal knowledge, my review of
`
`corporate records maintained by Samsung in the ordinary course of business, and/or my
`
`discussions with Samsung employees.
`
`4.
`
`SEC is a Korean corporation with a principal place of business in Suwon,
`
`Republic of Korea. SEC manufactures a wide range of consumer and enterprise electronic
`
`equipment and products such as semiconductors, personal computers, peripherals, monitors,
`
`televisions, home appliances, smartphones, tablets, and smart watches.
`
`5.
`
`SEC researches, designs, develops, and manufacturers Samsung phones and
`
`tablets.
`
`6.
`
`SEC employees responsible for managing the supply and commercial relationship
`
`with Google with respect to the Android Operating System and the accused Google Find My
`
`Device application are located in Korea.
`
`7.
`
`SEC does not research, design, or develop the accused Google Find My Device
`
`application. This application is created and supplied to SEC by Google.
`
`8.
`
`SEC does not have any employees (in the EDTX or elsewhere) who research,
`
`design, develop, or have access to any of Google’s proprietary documentation or proprietary
`
`source code for the accused Google Find My Device application.
`
` I
`
` declare under penalty of perjury under the laws of the United States that the foregoing is
`
`true and correct to the best of my knowledge. Executed in Gumi-si, Republic of Korea on July 21,
`
`2023.
`
`2
`
`
`
`Case 2:22-cv-00263-JRG-RSP Document 123-4 Filed 09/07/23 Page 3 of 3 PageID #:
`10114
`
`
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