`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Plaintiff,
`
`Defendant.
`
`Case No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`DECLARATION OF GEOFF CULBERTSON IN SUPPORT OF
`PLAINTIFF MAXELL, LTD.’S OPPOSITION TO APPLE INC.’S
`AMENDED MOTION TO TRANSFER VENUE PURSUANT TO 28 U.S.C.
`§ 1404(a)
`
`I, Geoff Culbertson, declare as follows.
`
`1.
`
`I am an attorney with the law firm of Patton Tidwell & Culbertson, LLP. I am
`
`admitted to the bar of the State of Texas. I represent Plaintiff Maxell, Ltd. in the above-captioned
`
`action.
`
`2.
`
`I am submitting this declaration on behalf of Maxell in support of its Opposition
`
`to Apple Inc.’s Amended Motion to Transfer Venue Pursuant to 28 U.S.C. § 1404 (Dkt. No. 57).
`
`3.
`
`I also represented Plaintiff Maxell, Ltd. in the matter of Maxell Ltd. v. ZTE (USA)
`
`Inc., No. 5:16-cv-00179-RWS (E.D. Tex.), including as trial counsel. In my representative
`
`capacity in that case, I was entrusted with possession of numerous documents relating to Maxell
`
`and Maxell’s patent licensing practice, including documents related to ownership of the patents,
`
`damages, Maxell’s licensing history, prosecution history, and inventorship.
`
`4.
`
`Those documents are still in my possession, stored physically and electronically at
`
`my offices in Texarkana.
`
`- 1 -
`
`PUBLIC VERSION
`
`
`
`Case 5:19-cv-00036-RWS Document 66-53 Filed 08/27/19 Page 2 of 2 PageID #: 3601
`
`5.
`
`I hereby declare under penalty of perjury that the foregoing statements are true
`
`and accurate to the best of my knowledge, information, and belief.
`
`Executed on August 23, 2019
`
`Geoff Culbertson
`
`_____
`
`- 2 -
`
`PUBLIC VERSION
`
`
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