`Case 2:22-cv-00280-RWS-RSP Document 106 Filed 08/29/23 Page 1 of 4 PageID #: 29480
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`AX WIRELESS LLC,
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`Plaintiff,
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`v.
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`LENOVO GROUP LIMITED,
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`Defendant.
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`Civil Action No. 2:22-cv-00280-RWS-RSP
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`JURY TRIAL DEMANDED
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`DECLARATION OF JANICE L. TA IN SUPPORT OF LENOVO GROUP LIMITED’S
`REPLY IN SUPPORT OF ITS OPPOSED MOTION TO DISMISS FIRST AMENDED
`COMPLAINT FOR LACK OF PERSONAL JURISDICTION AND
`MOTION TO DISMISS DIRECT INFRINGEMENT CLAIMS
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`I, Janice L. Ta, hereby declare as follows:
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`1.
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`I am admitted to practice in the Eastern District of Texas (“EDTX”) and am a partner
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`at the law firm of Perkins Coie, LLP, counsel of record for Lenovo Group Limited (“LGL”) in the
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`above-captioned action. I submit this declaration in support of LGL’s Reply in Support of Its
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`Opposed Motion to Dismiss First Amended Complaint for Lack of Personal Jurisdiction and Motion
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`to Dismiss Direct Infringement Claims in the above-captioned matter. I am competent to make this
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`declaration and all statements herein are true and correct to the best of my personal knowledge.
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`2.
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`Attached hereto as Exhibit A is a true and correct copy of excerpts of the transcript
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`of Adrian Chim’s 30(b)(6) deposition on behalf of LGL in this action, taken on August 4, 2023. This
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`exhibit is marked CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY under the Stipulated
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`Protective Order (Dkt. 50) in this action and is filed under seal.
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`3.
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`Attached hereto as Exhibit B is a true and correct copy of excerpts of the transcript
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`of Kurt Cranor’s 30(b)(6) deposition on behalf of Lenovo (United States), Inc. (“Lenovo U.S.”) in
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`Case 2:22-cv-00280-RWS-RSP Document 106 Filed 08/29/23 Page 2 of 4 PageID #: 29481
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`this action, taken on August 9, 2023. This exhibit is marked CONFIDENTIAL - OUTSIDE
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`ATTORNEYS’ EYES ONLY under the Stipulated Protective Order (Dkt. 50) in this action and is
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`filed under seal.
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`4.
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`Attached hereto as Exhibit C is a true and correct copy of excerpts of the transcript
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`of Kenneth Russell’s 30(b)(6) deposition on behalf of Motorola Mobility LLC (“Motorola”) in this
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`action, taken on August 15, 2023. This exhibit is marked CONFIDENTIAL - OUTSIDE
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`ATTORNEYS’ EYES ONLY under the Stipulated Protective Order (Dkt. 50) in this action and is
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`filed under seal.
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`5.
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`Attached hereto as Exhibit D is a true and correct copy of Adrian Chim’s declaration
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`in support of LGL’s Motion to Dismiss First Amended Complaint for Lack of Personal Jurisdiction
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`and Motion to Dismiss Direct Infringement Claims (Dkt. 35-7), executed and filed on January 17,
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`2023.
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`6.
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`Attached hereto as Exhibit E is a true and correct copy of a list of the officers and
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`directors of LGL, filed as Exhibit A to Adrian Chim’s declaration in support of LGL’s Motion to
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`Dismiss (Dkt 35-8) on January 17, 2023.
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`7.
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`Attached hereto as Exhibit F is a true and correct copy of a list of the officers and
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`directors of Lenovo U.S., filed as Exhibit B to Adrian Chim’s declaration in support of LGL’s Motion
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`to Dismiss (Dkt 35-9) on January 17, 2023.
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`8.
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`Attached hereto as Exhibit G is a true and correct copy of a list of the officers and
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`directors of Motorola, filed as Exhibit C to Adrian Chim’s declaration in support of LGL’s Motion
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`to Dismiss (Dkt 35-10) on January 17, 2023.
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`9.
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`Attached hereto as Exhibit H is a true and correct copy of a list of the officers and
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`directors of Lenovo PC HK Limited, filed as Exhibit E to Adrian Chim’s declaration in support of
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`LGL’s Motion to Dismiss (Dkt 35-12) on January 17, 2023.
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`Case 2:22-cv-00280-RWS-RSP Document 106 Filed 08/29/23 Page 3 of 4 PageID #: 29482
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`10.
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`Attached hereto as Exhibit I is a true and correct copy of excerpts of LGL’s Amended
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`Objections and Responses to AX Wireless’s Jurisdictional Interrogatories (No. 5), served on June
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`21, 2023. This exhibit is marked CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY under
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`the Stipulated Protective Order (Dkt. 50) in this action and is filed under seal.
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`11.
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`Attached hereto as Exhibit J is a true and correct copy of excerpts of LGL’s
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`2022/2023 Annual Report.
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`12.
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`Attached hereto as Exhibit K is a true and correct copy of the distribution agreement
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`between Lenovo PC HK Limited and Lenovo U.S. effective as of January 14, 2013, produced to AX
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`Wireless in this action at bates number LEN_AX000833. This exhibit is marked CONFIDENTIAL
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`- OUTSIDE ATTORNEYS’ EYES ONLY under the Stipulated Protective Order (Dkt. 50) in this
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`action and is filed under seal.
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`13.
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`Attached hereto as Exhibit L is a true and correct copy of the purchase agreement
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`between Motorola and Motorola (Wuhan) Mobility Technologies Communication Co., Ltd. effective
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`as of January 1, 2015, produced to AX Wireless in this action at bates number MMLUS000001608.
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`This exhibit is marked CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY under the
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`Stipulated Protective Order (Dkt. 50) in this action and is filed under seal.
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`14.
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`Attached hereto as Exhibit M is a true and correct copy of a supplemental declaration
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`of Kurt Cranor of Lenovo U.S. in support of a motion to dismiss from a prior case, American Patents
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`LLC v. MediaTek, et al., No. 6:18-CV-339 in the Western District of Texas, dated March 5, 2019,
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`produced to AX Wireless in this action at bates number LEN_AX000373. This exhibit is marked
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`CONFIDENTIAL - OUTSIDE ATTORNEYS’ EYES ONLY under the Stipulated Protective Order
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`(Dkt. 50) in this action and is filed under seal.
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`I declare under penalty of perjury under the laws of the United States of America that to the
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`best of my knowledge and recollection, the foregoing is true and correct.
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`Case 2:22-cv-00280-RWS-RSP Document 106 Filed 08/29/23 Page 4 of 4 PageID #: 29483
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`EXECUTED this 28th day of August, 2023, in Austin, Texas.
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`/s/
`Janice L. Ta
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