`10309
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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’S MOTION TO
`STAY PENDING RESOLUTION OF SAMSUNG’S MOTION TO SEVER AND
`TRANSFER TO THE NORTHERN DISTRICT OF CALIFORNIA CLAIMS AGAINST
`GOOGLE FIND MY DEVICE
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`Case 2:22-cv-00263-JRG-RSP Document 124-1 Filed 09/07/23 Page 2 of 3 PageID #:
`10310
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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”) in the above captioned
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`matter.
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`2.
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`I submit this declaration in support of Samsung’s Motion to Stay Pending
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`Resolution of Samsung’s Motion to Sever and Transfer to the Northern District of California
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`Claims Against Google Find My Device, filed concurrently herewith. I have personal
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`knowledge of the statements set forth in this declaration and, if called as a witness, would testify
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`competently.
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`3.
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`Attached hereto as Exhibit A is a true and correct copy of the cover pleading to
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`AGIS’s December 1, 2022 Disclosure of Asserted Claims and Infringement Contentions served
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`in this Case (Eastern District of Texas Case No. 2:22-CV-00263-JRG-RSP), with cited sections
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`highlighted.
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`4.
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`Attached hereto as Exhibit B is a true and correct copy of excerpts from AGIS’s
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`November 2022 ITC complaint against Google, Samsung, OnePlus, TCL, Lenovo, Motorola,
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`HMD, Sony, ASUS, Caterpillar, BLU, Panasonic, Kyocera, and Xiaomi (Inv. No. 337-TA-
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`1347), with cited sections highlighted.
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`5.
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`Attached hereto as Exhibit C is a true and correct copy of excerpts from the
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`transcript for the August 22, 2023 hearing in this Case (Eastern District of Texas Case No. 2:22-
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`CV-00263-JRG-RSP), with cited sections highlighted.
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` I
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` declare under penalty of perjury that the foregoing is true and correct. Executed in San
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`Francisco, California on September 6, 2023.
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`2
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`Case 2:22-cv-00263-JRG-RSP Document 124-1 Filed 09/07/23 Page 3 of 3 PageID #:
`10311
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`Dated: September 6, 2023
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`/s/ Mark Liang
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`Mark Liang
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`3
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