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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`OCEAN SEMICONDUCTOR LLC,
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`Plaintiff,
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`v.
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`HUAWEI DEVICE USA, INC., HUAWEI
`DEVICE CO., LTD., AND HISILICON
`TECHNOLOGIES CO., LTD.,
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`Defendants.
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`C.A. No. 4:20-cv-00991-ALM
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`DEMAND FOR JURY TRIAL
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`DECLARATION OF ALEX CHAN IN SUPPORT OF PLAINTIFF OCEAN
`SEMICONDUCTOR LLC’S OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS
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`I, Alex Chan, Esq., declare as follows:
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`1.
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`I am a partner at the Devlin Law Firm LLC. I am currently in good standing and
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`licensed to practice in the State of Texas and a member of the bar of this Court.
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`2.
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`I am counsel of record for Plaintiff Ocean Semiconductor LLC, (“Ocean”) in this
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`action, and make this Declaration in support of Ocean’s contemporaneously-filed Opposition to
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`Defendants Huawei Device USA, Inc., Huawei Device Co., Ltd., and HiSilicon Technologies
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`Co, Ltd.’s (“Huawei”) Motion to Dismiss for Failure to State a Claim Under 35 U.S.C. § 271(g).
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`3.
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`The facts set forth herein are true to my personal knowledge, and if called upon to
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`testify thereto, I could and would competently do so under oath.
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`4.
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`Attached as Exhibit 1 to this Declaration is a true and correct copy of Nvidia’s
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`Rule 12(b)(6) Motion to Dismiss Claims Under the ’538, ’305, and ’248 Patents Because
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`They Are Not Cognizable Under 35 U.S.C. § 271(g) (Dkt. 13), from the action captioned Ocean
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`Semiconductor LLC v. NVIDIA Corporation, Civil Action No. 6:20-cv-1211 (W.D. Tex.).
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`Case 4:20-cv-00991-ALM Document 14-1 Filed 04/19/21 Page 2 of 2 PageID #: 395
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`I declare under penalty of perjury under the laws of the United States that to the best of
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`my knowledge and recollection the foregoing is true and correct.
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`Executed this 19th day of April, 2021.
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`/s/ Alex Chan
`Alex Chan
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