Case 6:21-cv-01101-ADA Document 45-1 Filed 07/14/22 Page 1 of 5
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Case No. 6:21-cv-1101-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`DECLARATION OF DREW B. HOLLANDER IN SUPPORT OF PLAINTIFF
`AIRE TECHNOLOGY LTD.’S RESPONSE TO DEFENDANT’S
`MOTION TO TRANSFER VENUE UNDER 28 U.S.C. § 1404(a)
`
`
`AIRE TECHNOLOGY LTD.,
`
`
`
`
`
`APPLE INC.,
`
`
`
`
`v.
`
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`Defendant.
`
`
`
`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`Case No. 6:21-cv-1101-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`DECLARATION OF DREW B. HOLLANDER IN SUPPORT OF PLAINTIFF
`AIRE TECHNOLOGY LTD.’S RESPONSE TO DEFENDANT’S
`MOTION TO TRANSFER VENUE UNDER 28 U.S.C. § 1404(a)
`
`
`AIRE TECHNOLOGY LTD.,
`
`
`
`
`
`APPLE INC.,
`
`
`
`
`v.
`
`
`
`
`
`
`
`
`
`Plaintiff,
`
`
`
`Defendant.
`
`
`
`Case 6:21-cv-01101-ADA Document 45-1 Filed 07/14/22 Page 2 of 5
`
`I, Drew B. Hollander, hereby declare under the penalty of perjury as follows:
`
`1.
`
`I am an attorney at Russ August & Kabat LLP, counsel of record for Aire
`
`Technology Ltd. (“Aire”). I am one of the attorneys responsible for representing Aire in this
`
`matter. I have personal knowledge of all facts stated in this declaration and if called as a witness,
`
`could and would competently testify to these facts. I respectfully submit this declaration in support
`
`of Aire’s Response to Defendant’s Motion to Transfer Venue Under 28 U.S.C. § 1404(a).
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of the LinkedIn profile of
`
`Divya Patnaik, located at https://www.linkedin.com/in/divyapatnaik/.
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of the LinkedIn profile of
`
`Jola Fatokum, located at https://www.linkedin.com/in/jolaolufatokun/?jobid=1234.
`
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of the LinkedIn profile of
`
`Michael Gwinn, located at https://www.linkedin.com/in/michael-gwinn-85a61110b/?jobid=1234.
`
`5.
`
`Attached hereto as Exhibit 4 is a true and correct copy of the LinkedIn profile of
`
`Robert Aguirre, located at https://www.linkedin.com/in/robertroy/?jobid=1234.
`
`6.
`
`Attached hereto as Exhibit 5 is a true and correct copy of the LinkedIn profile of
`
`Miguel Gamez
`
`III,
`
`located
`
`at
`
`
`
`https://www.linkedin.com/in/miguel-gamez-iii-
`
`9734611ba/?jobid=1234.
`
`7.
`
`Attached hereto as Exhibit 6 is a true and correct copy of the LinkedIn profile of
`
`Kim Tryggestad, located at https://www.linkedin.com/in/kimtrygg/.
`
`8.
`
`Attached hereto as Exhibit 7 is a true and correct copy of the LinkedIn profile of
`
`Leah Peterson, located at https://www.linkedin.com/in/leah-peterson-20967351/.
`
`9.
`
`Attached hereto as Exhibit 8 is a true and correct copy of the LinkedIn profile of
`
`Zach Marshall, located at https://www.linkedin.com/in/zach-marshall-0a623a67/.
`
`
`
`1
`
`
`
`Case 6:21-cv-01101-ADA Document 45-1 Filed 07/14/22 Page 3 of 5
`
`10.
`
`Attached hereto as Exhibit 9 is a true and correct copy of the LinkedIn profile of
`
`Jennifer Cervantes, located at https://www.linkedin.com/in/jcervantes/.
`
`11.
`
`Attached hereto as Exhibit 10 is a true and correct copy of the LinkedIn profile of
`
`Alexander Antunovic, located at https://www.linkedin.com/in/alexander-antunovic/.
`
`12.
`
`Attached hereto as Exhibit 11 is a true and correct copy of the LinkedIn profile of
`
`John Alexander, located at https://www.linkedin.com/in/jalxr/.
`
`13.
`
`Attached hereto as Exhibit 12 is a true and correct copy of the LinkedIn profile of
`
`Stephanie Ponkoney, located at https://www.linkedin.com/in/stephanieponkoney/?jobid=1234.
`
`14.
`
`Attached hereto as Exhibit 13 is a true and correct copy of the LinkedIn profile of
`
`Mohamad Noah El-Zein, located at https://www.linkedin.com/in/mohamad-noah-el-zein-
`
`480a45134/.
`
`15.
`
`Attached hereto as Exhibit 14 is a true and correct copy of the LinkedIn profile of
`
`Adithya Sreekumar, located at https://www.linkedin.com/in/adithyasreekumar/.
`
`16.
`
`Attached hereto as Exhibit 15 is a true and correct copy of the LinkedIn profile of
`
`Octavian Laies, located at https://www.linkedin.com/in/octavian-laies-59a1141b/.
`
`17.
`
`Attached hereto as Exhibit 16 is a true and correct copy of the LinkedIn profile of
`
`Kinal Nikam, located at https://www.linkedin.com/in/kunalnikam/.
`
`18.
`
`Attached hereto as Exhibit 17 is a true and correct copy of the LinkedIn profile of
`
`Prachi Yaduwanshi, located at https://www.linkedin.com/in/prachiyaduwanshi/.
`
`19.
`
`Attached hereto as Exhibit 18 is a true and correct copy of the LinkedIn profile of
`
`Kenneth Lancaster, located at https://www.linkedin.com/in/kennethlancaster/.
`
`20.
`
`Attached hereto as Exhibit 19 is a true and correct copy of the LinkedIn profile of
`
`Ariel Fertman, located at https://www.linkedin.com/in/arielfertman/.
`
`
`
`2
`
`
`
`Case 6:21-cv-01101-ADA Document 45-1 Filed 07/14/22 Page 4 of 5
`
`21.
`
`Attached hereto as Exhibit 20 is a true and correct copy of the LinkedIn profile of
`
`Kevin Kissane, located at https://www.linkedin.com/in/kevin-kissane-2361527a/.
`
`22.
`
`Attached hereto as Exhibit 21 is a true and correct copy of the LinkedIn profile of
`
`Niranjan Mohan, located at https://www.linkedin.com/in/niranjan-mohan-26392422/.
`
`23.
`
`Attached hereto as Exhibit 22 is a true and correct copy of the LinkedIn profile of
`
`Abdullah Rababah, located at https://www.linkedin.com/in/arababah/.
`
`24.
`
`Attached hereto as Exhibit 23 is a true and correct copy of the LinkedIn profile of
`
`Dom Neill, located at https://www.linkedin.com/in/domneill/.
`
`25.
`
`Attached hereto as Exhibit 24 is a true and correct copy of the LinkedIn profile of
`
`Dongjun Lim, located at https://www.linkedin.com/in/dongjun-lim/.
`
`26.
`
`Attached hereto as Exhibit 25 is a true and correct copy of the LinkedIn profile of
`
`Adam Santillana, located at https://www.linkedin.com/in/adam-santillana-a87490139/.
`
`27.
`
`Attached hereto as Exhibit 26 is a true and correct copy of the LinkedIn profile of
`
`Maheshwar Dattatri, located at https://www.linkedin.com/in/maheshwar-dattatri-b706414/.
`
`28.
`
`Attached hereto as Exhibit 27 is a true and correct copy of the LinkedIn profile of
`
`Arvind Subramanian, located at https://www.linkedin.com/in/arvind-subramanian-72537914/.
`
`29.
`
`Attached hereto as Exhibit 28 is a true and correct copy of the LinkedIn profile of
`
`Jose Correa, located at https://www.linkedin.com/in/josecorreap/.
`
`30.
`
`Attached hereto as Exhibit 29 is a true and correct copy of the LinkedIn profile of
`
`Changhae Park, located at https://www.linkedin.com/in/changhae-park-8835948/.
`
`31.
`
`Attached hereto as Exhibit 30 is a true and correct copy of Apple’s Preliminary
`
`Invalidity Contentions, dated March 31, 2022.
`
`
`
`3
`
`
`
`Case 6:21-cv-01101-ADA Document 45-1 Filed 07/14/22 Page 5 of 5
`
`32.
`
`Attached hereto as Exhibit 31 is a true and correct copy of the LinkedIn profile of
`
`Jennifer Wuamett, located at https://www.linkedin.com/in/jenniferwuamett/.
`
`33.
`
`Attached hereto as Exhibit 32 is a true and correct copy of U.S. Patent Application
`
`Publication No. 2002/0095389, dated July 18, 2002.
`
`34.
`
`Attached hereto as Exhibit 33 is a true and correct copy of websites showing Robert
`
`Vallee Gaines current residence, located at https://www.whitepages.com/phone/1-432-684-8805
`
`and
`
`https://checkpeople.com/name/Robert-Gaines/in-
`
`TX/Midland/a14895f396fc4d3298ba6d59f948b4ab.
`
`35.
`
`Attached hereto as Exhibit 34 is a true and correct copy of U.S. Patent No.
`
`6,091,835, dated July 18, 2000.
`
`36.
`
`Attached hereto as Exhibit 35 is a true and correct copy of the LinkedIn profile of
`
`Benjamin Wright, located at https://www.linkedin.com/in/benjamin-l-wright.
`
`
`
`Executed on this 7th day of July, 2022 in Ardsley, NY.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/ Drew B. Hollander
`Drew B. Hollander
`
`
`
`
`4
`
`
`
`
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
