Case 2:22-cv-00263-JRG-RSP Document 137-1 Filed 10/02/23 Page 1 of 4 PageID #:
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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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`SAMSUNG ELECTRONICS CO., LTD. and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
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`Defendant.
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`CIVIL ACTION NO. 2:22-cv-263-JRG
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` JURY TRIAL DEMANDED
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`DECLARATION OF MARK LIANG IN SUPPORT OF SAMSUNG’S REPLY IN
`SUPPORT OF 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 137-1 Filed 10/02/23 Page 2 of 4 PageID #:
`12834
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`I, Mark Liang, declare and state as follows:
`I am a Partner at O’Melveny & Myers LLP, counsel for Defendants Samsung
`1.
`Electronics Co. Ltd. and Samsung Electronics America, Inc. (“Samsung”) in the above captioned
`matter.
`I submit this declaration in support of Samsung’s Reply in Support of Motion to
`2.
`Sever Claims Based on Google’s Find My Device and Transfer Those Claims to the Northern
`District of California, filed concurrently herewith. I have personal knowledge of the statements
`set forth in this declaration and, if called as a witness, would testify competently.
`Attached hereto as Exhibit T is a true and correct copy of AGIS’s July 21, 2023
`3.
`Exhibit C1 claim chart for U.S. Patent No. 8,213,970 to AGIS’s Disclosure of Asserted Claims
`and Infringement Contentions in this case, AGIS Software Development LLC v. Samsung
`Electronics Co. Ltd. and Samsung Electronics America, Inc., No. 2:22-CV-00263-JRG-RSP.
`Attached hereto as Exhibit U is a true and correct copy of AGIS’s July 21, 2023
`4.
`Exhibit D1 claim chart for U.S. Patent No. 9,467,838 to AGIS’s Disclosure of Asserted Claims
`and Infringement Contentions in this case, AGIS Software Development LLC v. Samsung
`Electronics Co. Ltd. and Samsung Electronics America, Inc., No. 2:22-CV-00263-JRG-RSP.
`Attached hereto as Exhibit V is a true and correct copy of AGIS’s July 21, 2023
`5.
`Exhibit C2 claim chart for U.S. Patent No. 8,213,970 to AGIS’s Disclosure of Asserted Claims
`and Infringement Contentions in this case, AGIS Software Development LLC v. Samsung
`Electronics Co. Ltd. and Samsung Electronics America, Inc., No. 2:22-CV-00263-JRG-RSP.
`Attached hereto as Exhibit W is a true and correct copy of AGIS’s July 21, 2023
`6.
`Exhibit D2 claim chart for U.S. Patent No. 9,467,838 to AGIS’s Disclosure of Asserted Claims
`and Infringement Contentions in this case, AGIS Software Development LLC v. Samsung
`Electronics Co. Ltd. and Samsung Electronics America, Inc., No. 2:22-CV-00263-JRG-RSP.
`Attached hereto as Exhibit X is a true and correct copy of AGIS’s March 23,
`7.
`2020 infringement contention claim chart for U.S. Patent No. 8,213,970 in AGIS Software
`Development LLC v. Google LLC, No. 2:19-CV-00361-JRG.
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`Case 2:22-cv-00263-JRG-RSP Document 137-1 Filed 10/02/23 Page 3 of 4 PageID #:
`12835
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`Attached hereto as Exhibit Y is true and correct copy of AGIS’s March 23, 2020
`8.
`infringement contention claim chart for U.S. Patent No. 9,467,838 in AGIS Software
`Development LLC v. Google LLC, No. 2:19-CV-00361-JRG.
`Attached hereto as Exhibit Z is a true and correct copy of AGIS’s July 7, 2023
`9.
`Subpoena to Google LLC in this case, AGIS Software Development LLC v. Samsung Electronics
`Co. Ltd. and Samsung Electronics America, Inc., No. 2:22-CV-00263-JRG-RSP.
`Attached hereto as Exhibit AA is a true and correct copy of AGIS’s July 7, 2023
`10.
`Subpoena to PAR Government Systems Corporation in this case, AGIS Software Development
`LLC v. Samsung Electronics Co. Ltd. and Samsung Electronics America, Inc., No. 2:22-CV-
`00263-JRG-RSP.
`Attached hereto as Exhibit BB is a true and correct copy of AGIS’s July 7, 2023
`11.
`Subpoena to Samsung SDS America, Inc. in this case, AGIS Software Development LLC v.
`Samsung Electronics Co. Ltd. and Samsung Electronics America, Inc., No. 2:22-CV-00263-JRG-
`RSP.
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`Attached hereto as Exhibit CC is a true and correct copy of AGIS Software
`12.
`Development LLC’s Response in Opposition to Samsung Electronics Co., Ltd. and Samsung
`Electronics America’s Motion to Transfer Venue in AGIS Software Development LLC v. Google
`LLC, Samsung Electronics Co. Ltd, and Samsung Electronics America, Inc., Nos. 2:19-CV-
`00361-JRG (Lead Case), 2:19-CV-00362-JRG (Consolidated Case), with cited sections
`highlighted. This copy was filed in the Google case, 2:19-CV-00361-JRG, as Dkt. 35.
`Attached hereto as Exhibit DD is true and correct copy of the Declaration of
`13.
`Malcolm K. Beyer, Jr., which was filed in opposition to Samsung Electronics Co., Ltd. and
`Samsung Electronics America’s Motion to Transfer Venue in AGIS Software Development LLC
`v. Google LLC, Samsung Electronics Co. Ltd, and Samsung Electronics America, Inc., Nos.
`2:19-CV-00361-JRG (Lead Case), 2:19-CV-00362-JRG (Consolidated Case). This copy was
`filed in the consolidated case, 2:19-CV-00361-JRG, as Dkt. 35 Ex. 1, and cited sections are
`highlighted.
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`Case 2:22-cv-00263-JRG-RSP Document 137-1 Filed 10/02/23 Page 4 of 4 PageID #:
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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 25, 2023.
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`Dated: September 25, 2023
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`/s/ Mark Liang
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`Mark Liang
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