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Case 6:21-cv-01101-ADA Document 25 Filed 04/14/22 Page 1 of 4
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`AIRE TECHNOLOGY, LTD.
`
`Plaintiff,
`
`
`
`
`
`
`
`v.
`
`APPLE INC.,
`
`
`
`
`
`Defendant.
`
`
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Case No. 6:21-cv-01101-ADA
`
`DECLARATION OF CASSANDRA ROTH IN SUPPORT OF
`DEFENDANT’S MOTION TO TRANSFER VENUE
`
`I, Cassandra Roth, declare as follows:
`
`1.
`
`I am admitted to this Court pro hac vice, and I am an associate of the law firm of
`
`Ropes and Gray LLP, counsel of record for Defendant Apple Inc. in this action.
`
`2.
`
`Attached as Exhibit A is a true and correct copy of the results of a search for
`
`“Aire Technology” as a taxable entity in Texas using the search functionality on the Texas’
`
`Secretary of State website at https://mycpa.cpa.state.tx.us/coa/coaSearchBtn, accessed on March
`
`23, 2022.
`
`3.
`
`Attached as Exhibit B is a true and correct copy of the patent assignment of the
`
`Asserted Patents from Giesecke+Devrient Mobile Security GmbH to Aire Technology Limited
`
`executed on September 13, 2021, which was obtained from the U.S.P.T.O’s Patent Assignment
`
`database.
`
`
`
`1
`
`

`

`Case 6:21-cv-01101-ADA Document 25 Filed 04/14/22 Page 2 of 4
`
`4.
`
`Attached as Exhibit C is a true and correct copy of NXP’s “NXP in the United
`
`States” website, available at https://www.nxp.com/company/about-nxp/worldwide-
`
`locations/united-states:USA, last accessed on March 23, 2022.
`
`5.
`
`Attached as Exhibit D is a true and correct copy of U.S. Patent No. 7,827,115,
`
`entitled “Online Payer Authentication Service,” issued on November 2, 2010, which was
`
`obtained from the USPTO’s Public Patent Application Information Retrieval (“Public PAIR”)
`
`system.
`
`6.
`
`Attached as Exhibit E is a true and correct copy of U.S. Patent Publication No.
`
`2006/0229998, entitled “Payment Via Financial Service Provider Using Network-Based
`
`Device,” which was obtained from the USPTO’s Public Patent Application Information Retrieval
`
`(“Public PAIR”) system.
`
`7.
`
`Attached as Exhibit F is a true and correct copy of an assignment agreement
`
`assigning the application published as U.S. Patent Publication No. 2006/0229998 from eBay,
`
`Inc. to Paypal, Inc, executed on July 17, 2015, which was obtained from the U.S.P.T.O’s Patent
`
`Assignment database.
`
`8.
`
`Attached as Exhibit G is a true and correct copy of a Visa Inc.’s Form 10-K
`
`Annual Report for the year ending September 30, 2021, which was obtained from the Security
`
`and Exchange Commission’s EDGAR database.
`
`9.
`
`Attached as Exhibit H is a true and correct copy of eBay Inc.’s “Contact Us”
`
`webpage, available at https://www.ebayinc.com/company/contact-us/, last accessed on March
`
`23, 2022.
`
`10.
`
`Attached as Exhibit I is a true and correct copy of Kevin Weller’s LinkedIn page,
`
`available at https://www.linkedin.com/in/kevin-weller, last accessed on March 23, 2022.
`
`
`
`2
`
`

`

`Case 6:21-cv-01101-ADA Document 25 Filed 04/14/22 Page 3 of 4
`
`11.
`
`Attached as Exhibit J is a true and correct copy of Tony Lewis’s LinkedIn page
`
`available at https://www.linkedin.com/in/tdlewis/, last accessed on March 23, 2022.
`
`12.
`
`Attached as Exhibit K is a true and correct copy of Ben Dominguez’s LinkedIn
`
`page, available at https://www.linkedin.com/in/ben-dominguez-6bb48a6/, last accessed on
`
`March 23, 2022.
`
`13.
`
`Attached as Exhibit L is a true and correct copy of Mark Harrison’s LinkedIn
`
`page, available at https://www.linkedin.com/in/markharrison4/, last accessed on March 23, 2022.
`
`14.
`
`Attached as Exhibit M is a true and correct copy of Mauria Finley’s LinkedIn
`
`page, available at https://www.linkedin.com/in/mauriafinley/, last accessed on March 23, 2022.
`
`15.
`
`Attached as Exhibit N is a true and correct copy of U.S. Patent No. 6,150,948,
`
`entitled “Low-Power Radio Frequency Identification Reader,” which was obtained from the
`
`USPTO’s Public Patent Application Information Retrieval (“Public PAIR”) system.
`
`16.
`
`Attached as Exhibit O is a true and correct copy of WIPO PCT Publication No.
`
`WO 00/52866, entitled “Portable Electronic Charge and Authorization Devices and Methods
`
`therefor,” which was obtained from WIPO’s PATENTSCOPE system.
`
`17.
`
`Attached as Exhibit P is a true and correct copy of Mohammad Anwar Khan’s
`
`LinkedIn page, available at https://www.linkedin.com/in/khanmx99/, last accessed on March 23,
`
`2022.
`
`18.
`
`Attached as Exhibit Q is a true and correct copy of Gisela Meister’s LinkedIn
`
`page, available at https://www.linkedin.com/in/dr-gisela-meister-
`
`b0710350/?originalSubdomain=de, last accessed on March 22, 2022.
`
`
`
`3
`
`

`

`Case 6:21-cv-01101-ADA Document 25 Filed 04/14/22 Page 4 of 4
`
`19.
`
`Attached as Exhibit R is a true and correct copy of Klaus Finkenzeller’s LinkedIn
`
`page, available at https://www.linkedin.com/in/klaus-finkenzeller-
`
`a66448103/?originalSubdomain=de, last accessed on March 22, 2022.
`
`20.
`
`Attached as Exhibit S is a true and correct copy of Nigol Martin’s LinkedIn page,
`
`available at https://www.linkedin.com/in/nigolmartin/?originalSubdomain=de, last accessed on
`
`March 22, 2022.
`
`21.
`
`Attached as Exhibit T is a true and correct copy of Denny Brandl’s LinkedIn
`
`page, available at https://www.linkedin.com/in/denny-brandl-2257aa22/?originalSubdomain=de,
`
`last accessed on March 22, 2022.
`
`22.
`
`Attached as Exhibit U is a true and correct copy of German Patent No. DE 10
`
`2018 001 565 A1, which was obtained from Espacenet.
`
`
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed on April 13, 2022.
`
`
`
`
`
`
`
`/s/ Cassandra Roth
`CASSANDRA ROTH
`
`4
`
`

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