Case 6:22-cv-00466-ADA-DTG Document 46-1 Filed 09/12/22 Page 1 of 4
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`ADVANCED SILICON
`TECHNOLOGIES LLC,
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`Plaintiff,
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`v.
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`NXP SEMICONDUCTORS N.V.,
`NXP B.V., and
`NXP USA, INC.,
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`Defendants.
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`Case. No. 6:22-CV-0466-ADA-DTG
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`DECLARATION OF ALLEN WAGNER IN SUPPORT OF NXP USA, INC.’S
`OPPOSED MOTION FOR INTRA-DISTRICT TRANSFER
`TO THE AUSTIN DIVISION OF THE WESTERN DISTRICT OF TEXAS
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`I, Allen Wagner, declare as follows:
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`1.
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`I make this declaration in support of NXP USA, Inc.’s (“NXP’s”) Motion for Intra-
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`District Transfer to the Austin Division of the Western District of Texas. I have personal
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`knowledge of the facts set forth herein and, if called upon to testify under oath, I could and would
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`competently testify thereto.
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`2.
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`I live in Pittsburgh, PA and my current title is Fellow and Chief Engineer – MCU
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`& MPU Products. I oversee the chip hardware development for the i.MX family of
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`microprocessors. I started with Motorola, Inc. (“Motorola”) in 1981 and transitioned to Freescale
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`Semiconductor, Inc. (“Freescale”) when it was divested from Motorola. I left Freescale for a short
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`time and moved to SigmaTEL Inc., which was then acquired by Freescale in 2008. I was employed
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`by Freescale when NXP acquired Freescale in 2015. I have been working on i.MX processors for
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`approximately 20 years.
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`Case 6:22-cv-00466-ADA-DTG Document 46-1 Filed 09/12/22 Page 2 of 4
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`3.
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`I lead a worldwide team of engineers and engineering leads that design the
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`integrated circuits for the i.MX processers, with the U.S.-based engineers located at NXP’s office
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`in Austin. I specifically oversee engineering leads that are in charge of the business unit for the
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`i.MX processors, Business Line-Edge Processing (“BL-EP”), that is headquartered in Austin.
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`Each engineering lead is responsible for orchestrating multi-faceted design projects with teams
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`that range from 50-100 engineers per team. I manage a total of 9 engineering leads, of which 3
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`engineering leads are U.S-based and are located in Austin and the other 6 engineering leads are
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`abroad. The 3 engineering leads in Austin execute design and development of the i.MX processors
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`from NXP’s Austin facilities. For example, the main engineering unit that supplies products to
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`BL-EP is the Microcontroller and Microprocessor Engineering (“MME”) and is located in Austin.
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`4.
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`Some integrated circuits within the i.MX processors, such as the video decoder and
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`graphics pipelines, are developed by third-parties. One such third party, Verisilicon, develops the
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`Vivante graphics processing unit. Verisilicon’s main offices are in Shanghai and San Jose;
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`Verisilicon also has an office Austin which has provided NXP with engineering support. Another
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`third party, Amphion/Allegro DVT, develops a video processing unit that is used in i.MX
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`processors. Amphion/Allegro DVT is headquartered in France.
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`5.
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`My team is not the only engineering team in Austin related to i.MX products. For
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`the i.MX processors, test program development includes approximately 60 employees that do
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`product and test engineering. The main site for test program development, including team
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`leadership, is Austin. Likewise, product engineering development is led from and executed in
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`Austin. The software teams, including codec and driver development (led by Jeff Kudrick),
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`comprises about 40 employees and is based in Austin. Applications support teams also include
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`Case 6:22-cv-00466-ADA-DTG Document 46-1 Filed 09/12/22 Page 3 of 4
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`about 40 employees and are based in Austin. Similarly, quality engineering teams are based in
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`Austin.
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`6.
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`NXP’s Austin headquarters also houses employees knowledgeable about the sales
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`(led by Ron Martino), sales finance (led by Srinath Rajen), marketing (led by Amanda McGregor),
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`competitive analysis (led by Gowri Chindalore and including a team of 2 employees), and global
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`logistics for the i.MX processors. Austin is also home to employees responsible for relevant
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`financial information, including teams led by Ray Henling, BL-EP Controller, and Tina Wheaton,
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`Chief of Staff and Business Manager BL-EP.
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`7.
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`NXP’s patent licensing team is also led out of Austin by Lee Chastain and includes
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`9 employees, with 7 located in Austin.
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`8.
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`NXP uses cloud-based repositories for storage of integrated circuit designs and
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`source code, and these repositories can be accessed from NXP’s locations in Austin. These
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`repositories for the i.MX processors are maintained by my team of engineering leads, including
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`the engineering leads that work at NXP’s facilities in Austin.
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`9.
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`Electronic versions of technical documentation relating to the work of the
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`engineering teams is stored on servers in Phoenix and Amsterdam. To the extent hard copies of
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`technical documents for the i.MX products exist, they are maintained by the engineers in Austin.
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`10.
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`NXP does not maintain offices or have any official presence in Bell, Bosque, Coryell,
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`Falls, Freestone, Hamilton, Hill, Leon, Limestone, McLennan, Milam, Robertson, or Somervell
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`counties of the State of Texas. NXP also does not maintain any documents relating to i.MX
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`processors in the counties.
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` I
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` declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Case 6:22-cv-00466-ADA-DTG Document 46-1 Filed 09/12/22 Page 4 of 4
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`Executed on September 12, 2022, in Pittsburg, PA
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` /s/ Allen Wagner
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`Allen Wagner
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