`Case 2:23-cv-00172-RWS-RSP Document 10-1 Filed 12/11/23 Page 1 of 4 PagelD#: 69
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`EXHIBIT A
`EXHIBIT A
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`
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE EASTERN DISTRICT OF TEXAS
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`MARSHALL DIVISION
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`SLYDE ANALYTICS, LLC.,
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`Plaintiff
`aintirt,
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`ZEPP HEALTH CORPORATION,
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`Defendant.
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`%
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`Case No. 2:23-cv-00172-RWS-RSP
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`JURY TRIAL DEMANDED
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`DECLARATION OF MIKE YAN YEUNG IN SUPPORT OF
`DEFENDANT’S MOTION TO TRANSFER
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`I, Mike Yan Yeung,declare as follows:
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`l.
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`I am the Chief Operating Officer (“COO”) of Defendant Zepp Health Corporation
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`(“ZHC”). Lam over twenty-one (21) years of age and reside in Fremont, CA. The statements herein
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`reflect my personal knowledge and belief based on information already known to me and/or
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`information learned from the investigation I conducted in connection with the preparation ofthis
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`declaration. If called to testify as a witness, I could testify competently thereto.
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`2.
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`I have acted as COO of ZHCsince 2015. Through my work as COO of ZHC,I have
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`developedfamiliarity and acquired knowledge regarding ZHC’s activities, as wellas the activities
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`of ZHC’s varies subsidiaries and their respective employees. In addition, in connection with the
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`preparation of this declaration, I reviewed documents and records of ZHC and interviewed some
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`employees of certain ZHC subsidiaries.
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`3.
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`ZHCis incorporated in the Cayman Islands and has a registered address of P.O.
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`Box 309, Ugland House, Grand Cayman, KY1-1104, CaymanIslands. ZHCis a holding company
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`and does notitself engage in any commercialactivities.
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`4.
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`5.
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`6.
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`ZHCdoesnot have a place of business in Texas.
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`ZHCdoes not have any employees in Texas.
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`ZHC has two direct subsidiaries that are incorporated in the State of Delaware:
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`Zepp,
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`Inc.; and Zepp North America,
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`Inc.
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`(“ZNA”). ZNA is responsible for distribution,
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`marketing, and sales in the United States of the smartwatch products accused of infringement by
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`Slyde Analytics, LLC. Zepp, Inc. is involved in the design of the smartwatch products accused of
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`infringement by Slyde Analytics, LLC.
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`be
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`Neither Zepp, Inc. nor ZNA hasa place of business in Texas. Zepp, Inc. and ZNA
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`each haveoffices in California: Zepp Inc.hasits office in Milpitas, CA; and ZNAhasits office in
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`Newport Beach, CA.
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`8.
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`ZNA does not have any employees in Texas. All of ZNA’s employeesreside in
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`California.
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`9.
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`Zepp, Inc. has a single employee in Texas: Maher Sarraj. Mr. Sarraj resides in
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`Dallas, Texas. Mr. Sarraj is a member of the Chip Division of Zepp, Inc. and he works on analog
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`chip design. Mr. Sarraj has not been, and is not currently, involved in any work related to any of
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`the smartwatch products accused of infringement by Slyde Analytics. LLC. All of Zepp, Inc.’s
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`remaining employeesreside in California.
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`10.
`Zepp, Inc. has also employed an independent contractor in Texas for work on IC
`layouts: Thomas Moore. Mr. Monte has not been,andis not currently, involved in any workrelated
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`to any of the smartwatch products accused of infringement by Slyde Analytics, LLC.
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`11.
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`Most of the documents and records of ZHC are stored and maintained on the cloud.
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`The individuals responsible for maintaining those documents and records are located in the
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`People’s Republic of China. ZHC has no documents or records stored or maintained anywhere in
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`the United States. The physical documents and records of ZHC,to the extent they exist, are stored
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`and maintained in the Cayman Islands or the People’s Republic of China.
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`12.
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`Most of the documents and records of both ZNA and Zepp, Inc. are stored and
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`maintained on the cloud. The individuals responsible for maintaining those documents and records
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`are located in the People’s Republic of China. The physical documents and records of both ZNA
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`and Zepp, Inc., to the extent they exist, are stored. and maintained in California.
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`13.
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`All of the smartwatch products accused of infringement by Slyde Analytics, LLC
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`were designed and developed in the People’s Republic of China and/or in California.
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`14._All of the smartwatch products accused of infringement by Slyde Analytics, LLC
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`were manufactured in the People’s Republic of China. No manufacturing was conducted in the
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`United States.
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`15.
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`[Thereby declarethat all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true; and further that these
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`statements were made with the knowledge that willful false statements and the like so made are
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`punishable by fine or imprisonment, or both, under the laws of perjury of the United States,
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`including Section 1001 of Title 18 of the United States Code.
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`17.
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`Executed this 10th day of December 2023, in Fremont, California.
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`Md,
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`Mike Yan Yeung
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