IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`§
`Case No. 6:21-cv-00984-ADA
`§
`
`§
`JURY TRIAL DEMANDED
`§
`
`§
`
`§
`§
`§
`§
`§
`§
`
`
`
`
`v.
`
`
`APPLE INC.,
`
`
`
`
`Defendant.
`
`Case 6:21-cv-00984-ADA Document 91-1 Filed 09/08/22 Page 1 of 5
`
`
`JAWBONE INNOVATIONS, LLC,
`
`
`Plaintiff,
`
`
`
`DECLARATION OF PETER LAMBRIANAKOS IN SUPPORT OF
`PLAINTIFF JAWBONE INNOVATIONS, LLC’S
`RESPONSE IN OPPOSITION TO DEFENDANT APPLE INC.’S MOTION
`TO TRANSFER VENUE TO THE NORTHERN DISTRICT OF CALIFORNIA (DKT. 38)
`
`
`I, Peter Lambrianakos, hereby declare as follows:
`
`1.
`
`I have personal knowledge of the facts set forth in this declaration. I am competent
`
`to testify as to all matters stated, and I am not under any legal disability which would in any way
`
`preclude me from testifying.
`
`2.
`
`I am a Partner at the law firm of Fabricant LLP and counsel of record for Plaintiff
`
`Jawbone Innovations, LLC, in this matter.
`
`3.
`
`The exhibits attached to this declaration may contain annotations and/or excerpts
`
`of the originals.
`
`4.
`
`Attached hereto as Exhibit 1 is a true and correct copy of the Declaration of York
`
`Eggleston, dated September 7, 2022.
`
`5.
`
`Attached hereto as Exhibit 2 is a true and correct copy of the Declaration of Daniel
`
`Setton, dated September 6, 2022.
`
`
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`§
`Case No. 6:21-cv-00984-ADA
`§
`
`§
`JURY TRIAL DEMANDED
`§
`
`§
`
`§
`§
`§
`§
`§
`§
`
`
`
`
`v.
`
`
`APPLE INC.,
`
`
`
`
`Defendant.
`
`Case 6:21-cv-00984-ADA Document 91-1 Filed 09/08/22 Page 1 of 5
`
`
`JAWBONE INNOVATIONS, LLC,
`
`
`Plaintiff,
`
`
`
`DECLARATION OF PETER LAMBRIANAKOS IN SUPPORT OF
`PLAINTIFF JAWBONE INNOVATIONS, LLC’S
`RESPONSE IN OPPOSITION TO DEFENDANT APPLE INC.’S MOTION
`TO TRANSFER VENUE TO THE NORTHERN DISTRICT OF CALIFORNIA (DKT. 38)
`
`
`I, Peter Lambrianakos, hereby declare as follows:
`
`1.
`
`I have personal knowledge of the facts set forth in this declaration. I am competent
`
`to testify as to all matters stated, and I am not under any legal disability which would in any way
`
`preclude me from testifying.
`
`2.
`
`I am a Partner at the law firm of Fabricant LLP and counsel of record for Plaintiff
`
`Jawbone Innovations, LLC, in this matter.
`
`3.
`
`The exhibits attached to this declaration may contain annotations and/or excerpts
`
`of the originals.
`
`4.
`
`Attached hereto as Exhibit 1 is a true and correct copy of the Declaration of York
`
`Eggleston, dated September 7, 2022.
`
`5.
`
`Attached hereto as Exhibit 2 is a true and correct copy of the Declaration of Daniel
`
`Setton, dated September 6, 2022.
`
`
`
`Case 6:21-cv-00984-ADA Document 91-1 Filed 09/08/22 Page 2 of 5
`
`6.
`
`Attached hereto as Exhibit 3 is a true and correct copy of the Declaration of Andrew
`
`Cohen, dated September 6, 2022.
`
`7.
`
`Attached hereto as Exhibit 4 is a true and correct copy of the Declaration of Sason
`
`Gabay, dated September 6, 2022.
`
`8.
`
`Attached hereto as Exhibit 5 is a true and correct copy of the Declaration of Keith
`
`Machen, dated September 6, 2022.
`
`9.
`
`Attached hereto as Exhibit 6 is a true and correct copy of the Declaration of Gregory
`
`Burnett, dated September 7, 2022.
`
`10.
`
`Attached hereto as Exhibit 7 is a true and correct copy of the Declaration of Michael
`
`Luna, Dkt. 73-7, dated August 16, 2022, in Jawbone Innovations, LLC v. Google LLC, Case No.
`
`6:21-cv-00985-ADA (W.D. Tex.).
`
`11.
`
`Attached hereto as Exhibit 8 is a true and correct copy of the Declaration of Scott
`
`S. Kokka, dated September 6, 2022.
`
`12.
`
`Attached hereto as Exhibit 9 is a true and correct copy of an article entitled “Apple
`
`announces plan to build new $1 billion campus in Austin” by Ben Tobin in USA Today dated
`
`December 13, 2018,
`
`taken
`
`from https://www.usatoday.com/story/tech/2018/12/13/apple-
`
`announces-plan-1-billion-campus-texas/2298296002/.
`
`13.
`
`Attached hereto as Exhibit 10 is a true and correct copy of an Apple press release
`
`entitled
`
`“Apple
`
`expands
`
`in Austin,” dated November 20, 2019,
`
`taken
`
`from
`
`https://www.apple.com/newsroom/2019/11/apple-expands-in-austin/.
`
`14.
`
`Attached hereto as Exhibit 11 is a true and correct copy of an Apple newsroom
`
`release entitled “Apple’s new MacPro to be made in Texas,” dated September 23, 2019, taken from
`
`https://www.apple.com/newsroom/2019/09/apples-new-mac-pro-to-be-made-in-texas/.
`
`2
`
`
`
`Case 6:21-cv-00984-ADA Document 91-1 Filed 09/08/22 Page 3 of 5
`
`15.
`
`Attached hereto as Exhibit 12 is a true and correct copy of an Apple press release
`
`entitled “Apple to build new campus in Austin and add jobs across the US,” dated December 13,
`
`2018,
`
`taken from https://www.apple.com/newsroom/2018/12/apple-to-build-new-campus-in-
`
`austin-and-add-jobs-across-the-us/.
`
`16.
`
`Attached hereto as Exhibit 13 is a true and correct copy of a screenshot of an
`
`KVUEabc story entitled “Apple’s northwest Austin campus reportedly adding $279M in new
`
`structures,” captured by FireShot Pro on September 7, 2022.
`
`17.
`
`Attached hereto as Exhibit 14 is a true and correct copy of Defendant Apple Inc.’s
`
`Supplemental Responses and Objections to Plaintiff Jawbone Innovations, LLC’s First Set of
`
`Venue Interrogatories (Nos. 1-4), dated July 29, 2022.
`
`18.
`
`Attached hereto as Exhibit 15 is a true and correct copy of excerpts from the
`
`transcript of the deposition of Scott Foster, taken August 19, 2022.
`
`19.
`
`Attached hereto as Exhibit 16 is a true and correct copy of excerpts from the
`
`transcript of the deposition of Emily Jones, taken August 25, 2022.
`
`20.
`
`Attached hereto as Exhibit 17 is a true and correct copy of excerpts from the
`
`transcript of the deposition of Shruti Sethi, taken August 22, 2022.
`
`21.
`
`Attached hereto as Exhibit 18 is a true and correct copy of the Address &
`
`Attorney/Agent Information for Application No. 10/667,207 retrieved from the USPTO Patent
`
`Center.
`
`22.
`
`Attached hereto as Exhibit 19 is a true and correct copy of Patent Application
`
`Information Retrieval for Application No. 10/159,770 retrieved from the USPTO Public Pair.
`
`23.
`
`Attached hereto as Exhibit 20 is a true and correct copy of Patent Application
`
`Information Retrieval for Application No. 12/163,617 retrieved from the USPTO Public Pair.
`
`3
`
`
`
`Case 6:21-cv-00984-ADA Document 91-1 Filed 09/08/22 Page 4 of 5
`
`24.
`
`Attached hereto as Exhibit 21 is a true and correct copy of Patent Application
`
`Information Retrieval for Application No. 10/400,282 retrieved from the USPTO Public Pair.
`
`25.
`
`Attached hereto as Exhibit 22 is a true and correct copy of the Address &
`
`Attorney/Agent Information for Application No. 12/606,140 from the USPTO Patent Center.
`
`26.
`
`Attached hereto as Exhibit 23 is a true and correct copy of the Address &
`
`Attorney/Agent Information for Application No. 12/606,146 retrieved from the USPTO Patent
`
`Center.
`
`27.
`
`Attached hereto as Exhibit 24 is a true and correct copy of Patent Application
`
`Information Retrieval for Application No. 12/139,333 retrieved from the USPTO Public Pair.
`
`28.
`
`Attached hereto as Exhibit 25 is a true and correct copy of excerpts from the
`
`transcript of the deposition of Richard Gregory, taken June 30, 2022.
`
`29.
`
`Attached hereto as Exhibit 26 is a true and correct copy of the Address &
`
`Attorney/Agent Information for Application No. 13/948,160 retrieved from the USPTO Patent
`
`Center.
`
`30.
`
`Attached hereto as Exhibit 27 is a true and correct copy of the Address &
`
`Attorney/Agent Information for Application No. 13/959,708 retrieved from the USPTO Patent
`
`Center.
`
`31.
`
`Attached hereto as Exhibit 28 is a true and correct copy of excerpts of the U.S.
`
`District Court – Judicial Caseload Profile, During the 12-Month Period Ending June 30, 2022 for
`
`the Western District of Texas and for the Northern District of California retrieved from
`
`https://www.uscourts.gov/sites/default/files/c05mar15_0.pdf.
`
`4
`
`
`
`Case 6:21-cv-00984-ADA Document 91-1 Filed 09/08/22 Page 5 of 5
`
`32.
`
`Attached hereto as Exhibit 29 is a true and correct copy of the Order Directing
`
`Parties to Inform Court Whether They Consent to Magistrate Judge for All Purposes in 10Tales
`
`Inc. v. TikTok Inc., No. 4:21-cv-3868-YGR, Dkt. 173 (N.D. Cal. June 10, 2022).
`
`33.
`
`Attached hereto as Exhibit 30 is a true and correct copy of a screenshot from the
`
`License Status of Barbara Bokanov Courtney taken from The State Bar of California web site on
`
`August 16, 2022.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed on September 8, 2022 in Short Hills, New Jersey.
`
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`
`
`/s/ Peter Lambrianakos
` Peter Lambrianakos
`
`
`
`5
`
`
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