`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`
`DEMARAY LLC,
`
`
`
`Plaintiff
`
`v.
`
`INTEL CORPORATION,
`
`Defendant.
`
`
`
`
`
`DEMARAY LLC,
`
`Case No. 6:20-cv-00634-ADA
`
`JURY TRIAL DEMANDED
`
`PUBLIC VERSION
`
`Plaintiff
`
`v.
`
`
`
`SAMSUNG ELECTRONICS CO., LTD (A
`KOREAN COMPANY), SAMSUNG
`ELECTRONICS AMERICA, INC.,
`SAMSUNG SEMICONDUCTOR, INC.,
`and SAMSUNG AUSTIN
`SEMICONDUCTOR, LLC,
`
`Defendants.
`
`Case No. 6:20-cv-00636-ADA
`
`JURY TRIAL DEMANDED
`
`PUBLIC VERSION
`
`
`
`
`
`
`
`
`DECLARATION OF BRIAN MARCUCCI IN SUPPORT OF PLAINTIFF DEMARAY
`LLC’S OPPPOSITIONS TO INTEL’S AND SAMSUNG’S MOTION TO TRANSFER
`VENUE
`
`
`
`10916605
`
`
`
`
`
`
`Case 6:20-cv-00636-ADA Document 59-1 Filed 03/02/21 Page 2 of 4
`Case 6:20-cv-00636-ADA Document 59-1 Filed 03/02/21 Page 2 of 4
`
`DECLARATION OF BRIAN MARCUCCI
`
`1, Brian Marcucci, declare as follows:
`
`1.
`
`I am President of Pmcipl Advisors, a consulting company working with Demaray
`
`LLC (“Demaray”). I submit this declaration in support of Demaray’s Oppositions to Intel’s and
`
`Samsung’s Motion to Transfer Venue. I have personal knowledge of the matters set forth in this
`
`declaration and, if called as a Witness, could testify to its contents.
`
`
`
`3.
`
`Before Prncipl Advisors, I have held various roles at companies associated with
`
`the semiconductor industry including Allied Inventors LLC, Intermolecular Inc, IPValue
`
`Management, Inc, Future Link Systems, LLC, Tessera, Inc, and Amkor Technology Inc. I have
`
`worked in and around the semiconductor industry for decades. Through my current and prior
`
`roles, I have extensive experience with intellectual property licensing and corporate
`
`development.
`
`
`
`5 .
`
`I am one of the principal persons working with Demaray in its various endeavors
`
`and have personal knowledge regarding those matters, including the persons and the documents
`
`related thereto.
`
`6.
`
`During my work with Demaray, we discovered that Intel and Samsung were using
`
`the patented technology in the Demaray patents at issue, without authorization, to manufacture
`
`thin films in electronic devices. Intel and Samsung semiconductor products consist largely of
`
`10916043
`
`‘ 1 ‘
`
`
`
`Case 6:20-cv-00636-ADA Document 59-1 Filed 03/02/21 Page 3 of 4
`Case 6:20-cv-00636-ADA Document 59-1 Filed 03/02/21 Page 3 of 4
`
`layer—upon—layer of thin films engineered and processed to create a very large number of
`
`interconnected transistors that together form microprocessors, memories or other semiconductor
`
`devices.
`
`7.
`
`The named inventors on the Demaray patents at issue are Dr. Hongmei Zhang,
`
`Mukundan Narasimhan, Dr. Ravi B. Mullapudi, and Dr. Richard E. Demaray. Dr. Demaray is
`
`Managing Member of Demaray LLC. Dr. Zhang and Mr. Narasimhan are consulting for
`
`Demaray LLC with regards to this litigation. Dr. Zhang is located in Boston, Massachusetts. Mr.
`
`Narasimhan is located in Bangalore, India.
`
`8.
`
`Further, I understand that both Dr. Demaray and Dr. Zhang are knowledgeable
`
`regarding the conception and reduction to practice of the inventions described in the Demaray
`
`patents at issue. While Dr. Demaray lives in Portola Valley, CA, he has confirmed that he is
`
`Willing and able to travel to Waco, TX, to attend trial in this matter. In addition, the Western
`
`District of Texas is closer to Boston than the Northern District of California, making the cost and
`
`convenience of travel to the Western District of Texas more favorable for Dr. Zhang.
`
`9.
`
`Demaray has used electronic document storage systems (e.g, Google Cloud and
`
`dropboxcom) to maintain its documents for many years. Currently, I maintain the most complete
`
`repository of information regarding Demaray, the Demaray patents at issue, Demaray’s
`
`predecessor in the Demaray patents at issue (Syrmnorphix Inc.), and this litigation at my
`
`residence in Phoenix, AZ. Many of these materials are also stored electronically on Google
`
`Cloud and dropboxcom and are accessible across the country.
`
`10916043
`
`' 2 '
`
`
`
`Case 6:20-cv-00636-ADA Document 59-1 Filed 03/02/21 Page 4 of 4
`Case 6:20-cv-00636-ADA Document 59-1 Filed 03/02/21 Page 4 of 4
`
`Executed on February 23, 2021 in Phoenix, AZ. I declare under penalty of perjury that
`
`the foregoing is true and correct to the best of my knowledge.
`
`
`
` Brian Marcucci
`
`10916043
`
`_ 3 _
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
