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`Case 3:18-cv-02838-K Document 22-1 Filed 09/25/17 Page 1 of 4 PageID 414Case 3:18-cv-02838-K Document 22-1 Filed 09/25/17 Page 1 of 4 PageID 414
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`Exhibit A
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`Case 3:18-cv-02838-K Document 22-1 Filed 09/25/17 Page 2 of 4 PageID 415Case 3:18-cv-02838-K Document 22-1 Filed 09/25/17 Page 2 of 4 PageID 415
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
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`Cypress Lake Software, Inc.,
`Plaintiff
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`v.
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`ZTE (USA) Inc., Defendant
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`
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`Case No. 6:17-cv-300-RWS
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`AFFIDAVIT OF JAMES RAY WOOD
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`I, James Ray Wood, declare under penalty of perjury as follows:
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`1. I am over the age of eighteen years and competent to make this declaration.
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`2. The facts stated in this Declaration are true and correct to the best of my
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`knowledge and belief.
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`3. I am employed in the role of Chief Patent Counsel for ZTE (USA) Inc.
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`4. ZTE (USA) Inc. is a New Jersey Corporation.
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`5. ZTE (USA) Inc.’s principal place of business is located in the Northern
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`District of Texas, at 2425 North Central Expressway, Suite 800, Richardson,
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`Texas.
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`6. ZTE (USA) Inc. has no regular and established place of business in the
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`Eastern District of Texas.
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`7. ZTE (USA) Inc. has no physical presence, such as a storefront, physical
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`facility, or owned, leased, or rented office space, in the Eastern District of
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`Texas.
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`8. ZTE (USA) Inc. has no bank accounts in the Eastern District of Texas.
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`1
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`Case 3:18-cv-02838-K Document 22-1 Filed 09/25/17 Page 3 of 4 PageID 416Case 3:18-cv-02838-K Document 22-1 Filed 09/25/17 Page 3 of 4 PageID 416
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`9. ZTE (USA) Inc. does not have a registered agent within the Eastern District
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`of Texas.
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`10. Independent customer service representatives work on ZTE (USA) Inc.’s
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`behalf out of a call center located in the Eastern District of Texas. These
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`independent customer service representatives are not employees of ZTE
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`(USA) Inc., they are employees of iQor, an independent company which is a
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`vendor to ZTE (USA) Inc. iQor services multiple other customers out of the
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`call center, and ZTE is not the largest customer iQor services out of the call
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`center.
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`11. ZTE USA does not own, lease, or rent the office space at the call center. ZTE
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`(USA) Inc. does not own the equipment, computers, furniture, or office
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`supplies for the call center. ZTE (USA) Inc. does not store products at the
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`call center.
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`12. iQor owns, operates, and controls the call center. ZTE employees may visit
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`the call center, but are not stationed there full time.
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`13. ZTE (USA) Inc. has no employee salespeople who operate out of their homes
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`within the Eastern District of Texas.
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`14. ZTE (USA) Inc. does have employee(s) who live in the Eastern District of
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`Texas, and one or more of those employee(s) may sometimes work from home,
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`but those homes are not ZTE (USA) Inc. “places of business” or “offices,” and
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`ZTE (USA) Inc. does not represent them, internally or externally, as places of
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`business of ZTE (USA) Inc. ZTE (USA) Inc. does not store company products
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`2
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`3
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`Case 3:18-cv-02838-K Document 22-1 Filed 09/25/17 Page 4 of 4 PageID 417Case 3:18-cv-02838-K Document 22-1 Filed 09/25/17 Page 4 of 4 PageID 417
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`in the homes of its employees and customers cannot obtain products from
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`ZTE (USA) Inc.’s employee home offices.
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`15. ZTE (USA) Inc. does not employ a secretarial service within the Eastern
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`District of Texas to assist employees working from their homes in the
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`Eastern District of Texas.
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`16. ZTE (USA) Inc. realizes no significant amount of direct revenue, nor
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`significant numbers of direct sales, to customers in the Eastern District of
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`Texas.
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`17. ZTE (USA) Inc. does not target the Eastern District of Texas with any non-
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`charitable marketing or promotional efforts. ZTE (USA) Inc. does engage in
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`generalized marketing and promotional efforts, but they are not targeted at
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`the Eastern District.
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` I
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` declare under penalty of perjury that the foregoing is true and correct. Executed
`on:
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`Date
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`By: James Ray Wood
` In House Counsel, ZTE (USA) Inc.
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`18 Sep 2017
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