Case 6:20-cv-00636-ADA Document 92-1 Filed 03/31/21 Page 1 of 3
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`
`
`DEMARAY LLC,
`
`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
`
`
`
`
`
`
`
`
`
`SUPPLEMENTAL DECLARATION OF C. MACLAIN WELLS IN SUPPORT OF
`PLAINTIFF DEMARAY LLC’S SUR-REPLY TO SAMSUNG’S MOTION TO
`TRANSFER VENUE
`
`
`
`10924259
`
`
`
`
`

`

`Case 6:20-cv-00636-ADA Document 92-1 Filed 03/31/21 Page 2 of 3
`
`
`
`
`
`DECLARATION OF C. MACLAIN WELLS
`
`I, C. Maclain Wells, declare as follows:
`
`
`
`I am counsel at the law firm of Irell & Manella LLP, counsel for Plaintiff
`
`Demaray LLC (“Demaray”). I am a member in good standing of the State Bar of California and
`
`have been duly licensed to practice law before all of the courts of the State of California, and
`
`have been admitted to practice pro hac vice before this Court. I submit this declaration in support
`
`of Demaray’s Sur-Reply to 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.
`
`
`
`Attached as Exhibit 23 is a true and correct copy of U.S. Patent No. 10,453,726.1
`
`The face of the patent indicates it is assigned to Applied Material’s, Inc. (“Applied”). The named
`
`inventors are located in Texas, and the patent relates to PVD chambers.
`
`
`
`Attached as Exhibit 24 is a true and correct copy of U.S. Patent No. 10,446,428.
`
`The face of the patent indicates it is assigned to Applied and the named inventor is located in
`
`Texas, and the patent relates to PVD chambers.
`
`
`
`Attached as Exhibit 25 is a true and correct copy of U.S. Patent No. 10,381,247.
`
`The face of the patent indicates it is assigned to Applied and has named inventors located in
`
`Texas, and the patent relates to PVD chambers.
`
`
`
`Attached as Exhibit 26 is a true and correct copy of U.S. Patent No. 10,056,274.
`
`The face of the patent indicates it is assigned to Applied Materials Israel Ltd. and has named
`
`inventors located in Texas, and the patent relates to PVD chambers.
`
`
`1 The numbering of this exhibit continues sequentially from that of the earlier filed
`Declaration of C. Maclain Wells in Support of Demaray LLC’s Opposition to Samsung’s Motion
`to Transfer Venue (Dkt. 51-1). There is no Exhibit 22 to maintain consistency with exhibit
`numbering in the Intel case.
`
`10924259
`
`
`- 1 -
`
`

`

`Case 6:20-cv-00636-ADA Document 92-1 Filed 03/31/21 Page 3 of 3
`
`
`
`
`
`Attached as Exhibit 27 is a true and correct copy of U.S. Patent No. 10,468,292.
`
`The face of the patent indicates it is assigned to Applied and one of the two named inventors is
`
`located in Texas, and the patent relates to PVD chambers.
`
`
`
`Attached as Exhibit 28 is a true and correct copy of U.S. Patent No. 5,879,467. A
`
`version of this patent was marked as Exhibit 12 to the Deposition of Brian Marcucci.
`
`
`
`Attached as Exhibit 29 is a true and correct copy of U.S. Patent No. 5,789,878. A
`
`version of this patent was marked as Exhibit 13 to the Deposition of Brian Marcucci.
`
`
`
`Attached as Exhibit 30 is a true and correct copy of the cover document for
`
`Defendants’ First Amended Preliminary Invalidity Contentions, which Defendants served on
`
`February 12, 2021.
`
`
`
`Attached as Exhibit 31 is a true and correct printout of
`
`https://www.eetimes.com/applied-materials-to-more-than-double-the-size-of-companys-primary-
`
`manufacturing-facilities/. A version of this web page was marked as Exhibit 11 to the Deposition
`
`of Brian Marcucci.
`
`
`
`Attached as Exhibit 32 is a true and correct printout of
`
`https://www.advancedenergy.com/contact-us/. A version of this web page was marked as Exhibit
`
`10 to the Deposition of Brian Marcucci.
`
`
`
`I understand that Brian Marcucci has confirmed that he is willing and able to
`
`travel to Waco, TX, to attend trial in this matter.
`
`Executed on March 31, 2021 in Sebastopol, California. I declare under penalty of perjury
`
`that the foregoing is true and correct.
`
`By: /s/ C. Maclain Wells
`C. Maclain Wells
`Attorneys for Plaintiff DEMARAY LLC
`
`10924259
`
`
`- 2 -
`
`