`Case 5:19-cv-00036—RWS Document 66-51 Filed 08/27/19 Page 1 of 4 PageID #: 3584
`PUBLIC VERSION
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
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`MAXELL, LTD.,
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`V.
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`APPLE INC,
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`
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`Plaintiff,
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`Defendant.
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`Case No. 5:19-cv-00036-RWS
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`JURY TRIAL DEMANDED
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`DECLARATION OF KENJI NAKAMURA IN SUPPORT OF MAXELL, LTD.’S
`OPPOSITION TO APPLE INC.’S AMENDED MOTION TO TRANSFER VENUE
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`PURSUANT TO 28 U.S.C. '
`
`I, Kenji Nakamura, hereby declare and state as follows:
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`1.
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`I am a Senior Engineer in the IP Department of Maxell, Ltd. (“Maxell”) and a
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`Director of Maxell Research and Development of America, LLC (“MRDA”).
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`I submit this
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`declaration in support of Maxell’s Opposition to Apple Inc.’s Amended Motion to Transfer
`
`Venue Pursuant to 28 U.S.C. §1404(a). I have personal knowledge of the statements herein, and,
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`if called to do so, I could and would testify competently as to the same.
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`
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`PUBLIC VERSION
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`
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`Case 5:19-cv-00036-RWS Document 66-51 Filed 08/27/19 Page 2 of 4 PageID #: 3585
`Case 5:19-cv-00036—RWS Document 66-51 Filed 08/27/19 Page 2 of 4 PageID #: 3585
`PUBLIC VERSION
`
`
`
`PUBLIC VERSION
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`
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`Case 5:19-cv-00036-RWS Document 66-51 Filed 08/27/19 Page 3 of 4 PageID #: 3586
`Case 5:19-cv-00036—RWS Document 66-51 Filed 08/27/19 Page 3 of 4 PageID #: 3586
`PUBLIC VERSION
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`
`
`PUBLIC VERSION
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`
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`Case 5:19-cv-00036-RWS Document 66-51 Filed 08/27/19 Page 4 of 4 PageID #: 3587
`Case 5:19-cv-00036—RWS Document 66-51 Filed 08/27/19 Page 4 of 4 PageID #: 3587
`PUBLIC VERSION
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`
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`I declare under penalty of perjury under the laws of the United States of America that the
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`above is true and correct and that this Declaration was executed on August 20, 2019 in Marshall,
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`Texas.
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`Dated: August 20, 2019
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`
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`By:
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`Ken‘j'i Nakamura
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`PUBLIC VERSION
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`
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