Case 6:21-cv-00984-ADA Document 39 Filed 05/02/22 Page 1 of 4
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`JAWBONE INNOVATIONS, LLC,
`
`Case No. 6:21-CV-00984-ADA
`
`
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`PATENT CASE
`
`JURY TRIAL DEMANDED
`
`Defendant.
`
`
`
`
`
`
`
`
`
`DECLARATION OF QIUYI WU IN SUPPORT OF DEFENDANT
`APPLE INC.’S MOTION TO TRANSFER VENUE TO
`THE NORTHERN DISTRICT OF CALIFORNIA
`
`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 Motion to Transfer Venue to the
`
`Northern District of California. I state that the following is true and correct to the best of my
`
`knowledge and belief.
`
`1.
`
`Attached hereto as Exhibit A is a true and correct copy of Plaintiff’s Disclosure of
`
`Asserted Claims and Infringement Contentions.
`
`2.
`
`Attached hereto as Exhibit B is a true and correct copy of the Declaration of Mark
`
`Rollins. (FILED UNDER SEAL)
`
`3.
`
`Attached hereto as Exhibit C is a true and correct copy of the LinkedIn Profile
`
`webpage of Nicolas Petit, retrieved from https://www.linkedin.com/in/nicolas-petit-348b2a4/ on
`
`April 28, 2022.
`
`4.
`
`Attached hereto as Exhibit D is a true and correct copy of the LinkedIn Profile
`
`webpage of Eric Zhinian Jing, retrieved from https://www.linkedin.com/in/eric-zhinian-jing-
`
`940a8012/ on April 28, 2022.
`
`
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`JAWBONE INNOVATIONS, LLC,
`
`Case No. 6:21-CV-00984-ADA
`
`
`
`Plaintiff,
`
`v.
`
`APPLE INC.,
`
`PATENT CASE
`
`JURY TRIAL DEMANDED
`
`Defendant.
`
`
`
`
`
`
`
`
`
`DECLARATION OF QIUYI WU IN SUPPORT OF DEFENDANT
`APPLE INC.’S MOTION TO TRANSFER VENUE TO
`THE NORTHERN DISTRICT OF CALIFORNIA
`
`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 Motion to Transfer Venue to the
`
`Northern District of California. I state that the following is true and correct to the best of my
`
`knowledge and belief.
`
`1.
`
`Attached hereto as Exhibit A is a true and correct copy of Plaintiff’s Disclosure of
`
`Asserted Claims and Infringement Contentions.
`
`2.
`
`Attached hereto as Exhibit B is a true and correct copy of the Declaration of Mark
`
`Rollins. (FILED UNDER SEAL)
`
`3.
`
`Attached hereto as Exhibit C is a true and correct copy of the LinkedIn Profile
`
`webpage of Nicolas Petit, retrieved from https://www.linkedin.com/in/nicolas-petit-348b2a4/ on
`
`April 28, 2022.
`
`4.
`
`Attached hereto as Exhibit D is a true and correct copy of the LinkedIn Profile
`
`webpage of Eric Zhinian Jing, retrieved from https://www.linkedin.com/in/eric-zhinian-jing-
`
`940a8012/ on April 28, 2022.
`
`
`
`
`
`
`
`Case 6:21-cv-00984-ADA Document 39 Filed 05/02/22 Page 2 of 4
`
`5.
`
`Attached hereto as Exhibit E is a true and correct copy the LinkedIn Profile
`
`webpage of Andrew Einaudi, retrieved from https://www.linkedin.com/in/andreweinaudi/ on
`
`April 28, 2022.
`
`6.
`
`Attached hereto as Exhibit F is a true and correct copy of the LexisNexis People
`
`Search Record for Eric F Breitfeller.
`
`7.
`
`Attached hereto as Exhibit G is a true and correct copy of the LinkedIn Profile
`
`webpage of Gregory Burnett, retrieved from https://www.linkedin.com/in/gregory-burnett-
`
`b05a474/ on April 28, 2022.
`
`8.
`
`Attached hereto as Exhibit H is a true and correct copy of the LinkedIn Profile
`
`webpage of Alexander Asseily, retrieved from https://www.linkedin.com/in/alexander-asseily-
`
`305a4994/ on April 28, 2022.
`
`9.
`
`Attached hereto as Exhibit I is a true and correct copy of the entity details of
`
`AliphCom, Inc., retrieved from the California Secretary of State website.
`
`10.
`
`Attached hereto as Exhibit J is a true and correct copy of the LinkedIn profile
`
`webpage of Hosain Rahman, retrieved from https://www.linkedin.com/in/hosainrahman/ on
`
`April 28, 2022.
`
`11.
`
`Attached hereto as Exhibit K is a true and correct copy of the LinkedIn profile
`
`webpage of Michael Luna, retrieved from https://www.linkedin.com/in/michaeleluna/ on April
`
`28, 2022.
`
`12.
`
`Attached hereto as Exhibit L is a true and correct copy of Amended and Restated
`
`Patent Security Agreement covering one or more of the Asserted Patents (produced as
`
`JAWBONE0000019-49 in this matter).
`
`
`
`2
`
`
`
`Case 6:21-cv-00984-ADA Document 39 Filed 05/02/22 Page 3 of 4
`
`13.
`
`Attached hereto as Exhibit M is a true and correct copy of the January 15, 2021
`
`Affidavit of Michael Luna submitted to the United States Patent and Trademark Office during
`
`the prosecution of U.S. Patent Application No. 13/959,708.
`
`14.
`
`Attached hereto as Exhibit N is a true and correct copy of the LinkedIn profile
`
`webpage of Richard (Rick) Gregory, retrieved from https://www.linkedin.com/in/rick-gregory-
`
`3a67b92b/ on April 28, 2022.
`
`15.
`
`Attached hereto as Exhibit O is a true and correct copy of the LinkedIn profile
`
`webpage of Barbara Courtney, retrieved from https://www.linkedin.com/in/barbara-courtney-
`
`b905418/ on April 28, 2022.
`
`16.
`
`Attached hereto as Exhibit P is a true and correct copy of AliphCom, Inc.’s Power
`
`of Attorney submitted to the United States Patent and Trademark Office during the prosecution
`
`of U.S. Patent Application No. 10/159,770, dated November 21, 2011.
`
`17.
`
`Attached hereto as Exhibit Q is a true and correct copy of the LinkedIn profile
`
`webpage of Scott Kokka, retrieved from https://www.linkedin.com/in/scottkokka/ on April 28,
`
`2022.
`
`18.
`
`Attached hereto as Exhibit R is a true and correct copy of the LinkedIn profile
`
`webpage of Trueman Denny, retrieved from https://www.linkedin.com/in/truemanhdennyiii/ on
`
`April 28, 2022.
`
`19.
`
`Attached hereto as Exhibit S is a true and correct copy of the LinkedIn profile
`
`webpage of Howard Yuan, retrieved from https://www.linkedin.com/in/hjyuan/ on April 28,
`
`2022.
`
`20.
`
`Attached hereto as Exhibit T is a true and correct copy of the EnvisionIP
`
`“Contact” website page, retrieved from http://envisionip.com/contact on April 27, 2022.
`
`
`
`3
`
`
`
`Case 6:21-cv-00984-ADA Document 39 Filed 05/02/22 Page 4 of 4
`
`21.
`
`Attached hereto as Exhibit U is a true and correct copy of the Texas Secretary of
`
`State Certificate of Formation for Jawbone Innovations, LLC, filed on February 1, 2021.
`
`22.
`
`Attached hereto as Exhibit V is a true and correct copy of flight information from
`
`Los Angeles, California (LAX) to San Francisco, California (SFO), accessed on March 22, 2022.
`
`23.
`
`Attached hereto as Exhibit W is a true and correct copy of flight information from
`
`Los Angeles, California (LAX) to Waco, Texas (ACT), accessed on March 22, 2022.
`
`24.
`
`Attached hereto as Exhibit X is a true and correct copy of photos of Jawbone
`
`Innovations, LLC’s alleged office at 2226 Washington Avenue, Suite Number 1, Waco, Texas
`
`76701.
`
`25.
`
`Attached hereto as Exhibit Y is a true and correct copy of the Lex Machina
`
`Western District of Texas Report for District Judge Alan D. Albright.
`
`26.
`
`Attached hereto as Exhibit Z is a true and correct copy of the Lex Machina
`
`Northern District of California Report.
`
`27.
`
`Attached hereto as Exhibit AA is a true and correct copy of the Northern District
`
`of California notice that “All Jury Trials Suspended Through January 26, 2022,” retrieved from
`
`https://cand.uscourts.gov/announcements/all-jury-trials-suspended-through-january-26-2022/ on
`
`February 23, 2022.
`
`28.
`
`Attached hereto as Exhibit AB is a true and correct copy of a February 23, 2022
`
`Law360 article by Bonnie Eslinger entitled “Sutter’s Market Dominance Hiked Premiums
`
`$411M, Jury Told.”
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed on
`
`May 2, 2022 in Needham, MA.
`
`
`
`
`
`
`
`/s/ Qiuyi Wu
`Qiuyi Wu
`
`
`
`
`
`
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`4
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