`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`JAWBONE INNOVATIONS, LLC,
`
`Case No. 6:21-CV-00984-ADA
`
`
`
`v.
`
`APPLE INC.,
`
`Plaintiff,
`
`Defendant.
`
`PATENT CASE
`
`JURY TRIAL DEMANDED
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`
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`
`
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`DECLARATION OF QIUYI WU IN SUPPORT OF DEFENDANT
`APPLE INC.’S REPLY IN SUPPORT OF ITS MOTION TO TRANSFER VENUE TO
`THE NORTHERN DISTRICT OF CALIFORNIA
`
`
`
`
`
`
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`Case 6:21-cv-00984-ADA Document 101-1 Filed 09/28/22 Page 2 of 3
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`I, Qiuyi Wu, am an associate at the firm of Fish & Richardson P.C., counsel of record for
`
`Apple Inc. I make this declaration in support of Apple Inc.’s Reply in Support of Its Motion to
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`Transfer Venue to the Northern District of California. I state that the following is true and
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`correct to the best of my knowledge and belief.
`
`1.
`
`Attached hereto as Exhibit 1 is a true and correct copy of Declaration of
`
`
`
` in Support of Defendant Apple Inc.’s Motion to Transfer Venue (produced as APL-
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`JAWBONE_00704556-00704558 in this matter). (FILED UNDER SEAL)
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`2.
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`Attached hereto as Exhibit 2 is a true and correct copy of Declaration of
`
`
`
`in Support of Defendant Apple Inc.’s Motion to Transfer Venue (produced as APL-
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`JAWBONE_00704559-00704561 in this matter). (FILED UNDER SEAL)
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`3.
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`Attached hereto as Exhibit 3 is a true and correct copy Declaration of
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`
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` in Support of Defendant Apple Inc.’s Motion to Transfer Venue (produced as APL-
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`JAWBONE_00704553-00704555 in this matter). (FILED UNDER SEAL)
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`4.
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`Attached hereto as Exhibit 4 is a true and correct copy of Declaration of
`
`
`
`in Support of Defendant Apple Inc.’s Motion to Transfer Venue (produced as APL-
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`JAWBONE_00704547-00704549 in this matter). (FILED UNDER SEAL)
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`5.
`
`Attached hereto as Exhibit 5 is a true and correct copy of Declaration of
`
`
`
`in Support of Defendant Apple Inc.’s Motion to Transfer Venue (produced as APL-
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`JAWBONE_00704544-00704546 in this matter). (FILED UNDER SEAL)
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`6.
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`Attached hereto as Exhibit 6 is a true and correct copy of
`
` in Support
`
`of Defendant Apple Inc.’s Motion to Transfer Venue (produced as APL-JAWBONE_00704550-
`
`00704552 in this matter). (FILED UNDER SEAL)
`
`
`
`1
`
`
`
`Case 6:21-cv-00984-ADA Document 101-1 Filed 09/28/22 Page 3 of 3
`
`7.
`
`Attached hereto as Exhibit 7 is a true and correct copy of highlighted excerpts of
`
`the transcript of
`
` deposition, conducted on August 19, 2022. (FILED UNDER
`
`SEAL)
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`8.
`
`Attached hereto as Exhibit 8 is a true and correct copy of highlighted excerpts of
`
`the transcript of
`
` deposition, conducted on August 25, 2022. (FILED UNDER
`
`SEAL)
`
`9.
`
`Attached hereto as Exhibit 9 is a true and correct copy of highlighted excerpts of
`
`the transcript of
`
` deposition, conducted on August 22, 2022. (FILED UNDER
`
`SEAL)
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`10.
`
`Attached hereto as Exhibit 10 is a true and correct copy of highlighted excerpts of
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`Jawbone Innovations, LLC’s Objections and Responses to Defendant Apple Inc.’s First Set of
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`Interrogatories (Nos. 1-15), dated September 7, 2022.
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`11.
`
`Attached hereto as Exhibit 11 is a true and correct copy of a webpage titled
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`“Judicial Emergencies,” retrieved from https://www.uscourts.gov/judges-judgeships/judicial-
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`vacancies/judicial-emergencies on September 20, 2022.
`
`12.
`
`Attached hereto as Exhibit 12 is a true and correct copy of an Order from United
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`States District Court for the Eastern District of Texas, Marshall Division, granting Amazon’s
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`motion to transfer venue, issued on September 21, 2022. Jawbone Innovations, LLC v. Amazon,
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`Civil Action No. 1:21-CV-00435-JRG, Dkt. 60 (September 21, 2022).
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`I declare under penalty of perjury that the foregoing is true and correct. Executed on
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`September 21, 2022 in Needham, MA.
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`
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`
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`/s/ Qiuyi Wu
`Qiuyi Wu
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`2
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