`Case 5:16-cv-00179—RWS Document 291-4 Filed 08/28/18 Page 1 of 2 PageID #: 18676
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`EXHIBIT C
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`EXHIBIT C
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`8/19/2018
`Case 5:16-cv-00179-RWS Document 291-4 Filed 08/28/18 Page 2 of 2 PageID #: 18677
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`Maxell, Ltd. v.
`ZTE USA Inc.
`Closing Argument
`
`June 29, 2018
`
`NAME 1
`
`Plaintiff Wants You to Focus on China, NOT ZTE USA
`
`MR. BEABER:
`…You may also know or have gathered that ZTE
`USA is the wholly owned subsidiary of its Chinese
`parent company, ZTE Corporation. Essentially, ZTE
`USA, the Defendant here, they sell smartphones in the
`United States, including right here in Texarkana, as
`you heard yesterday, on behalf of ZTE Corporation.
`
`Trial Transcript 06/19/18 AM 44:17–22
`
`MR. BEABER:
`…Now, in mid-2013, upon learning of ZTE's use
`of its patents, ZTE Corporation, the mother ship again,
`was contacted to engage in licensing discussions.
`Maxell provided detailed materials demonstrating
`ZTE's use.
`
`Trial Transcript 06/19/18 AM 58:25–59:3
`
`MR. BEABER:
`…In fact, as you'll learn from Mr. Nakamura,
`even with Maxell's urging for the last five-plus years,
`again through communications with ZTE Corporation,
`ZTE USA's mother ship, ZTE refuses to pay Maxell
`any reasonable amount for its use.
`Trial Transcript 06/19/18 AM 53:13–17
`
`MR. BEABER:
`…Since 2013, for three years before even filing
`this case, Maxell
`tried to convince ZTE through
`communications with ZTE Corporation, their mother
`ship, to do the right thing, to take a license
`
`Trial Transcript 06/19/18 AM 45:22–46:2
`
`MR. CULBERTSON:
`…And did Hitachi and Maxell understand ZTE
`Corp to be the mother ship?
`
`Trial Transcript 06/20/18 AM 74:9–14
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`3
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