Case 2:17-cv-00932-JLR Document 70 Filed 03/30/18 Page 1 of 3
`Case 2:17-cv-00932-JLR Document 70 Filed 03/30/18 Page 1 of 3
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`THE HONORABLE JAMES L. ROBART
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF WASHINGTON
`AT SEATTLE
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`CYWEE GROUP LTD.,
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`Plaintiff,
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`v.
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`HTC CORPORATION, and HTC AMERICA,
`INC,
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`Defendants.
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`CASE NO.: 2:17-cv-00932-JLR
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`DECLARATION OF CELESTE
`INGALLS REGARDING SERVICE
`0F PROCESS IN TAIWAN IN
`SUPPORT OF DEFENDANTS,
`MOTION TO AMEND SCHEDULING
`RDER
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`O
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`15 HTC CORPORATION, and HTC AMERICA,
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`INC,
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`V.
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`Third-Party Plaintiffs,
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`STMicroelectronics N.V., STMicroelectronics,
`Inc., and CyWee Motion Group Ltd.,
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`Third-Party Defendants.
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`DECLARATION OF CELESTE INGALLS
`.
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`_
`_
`CASE NO. 2.17 CV 00932 JLR
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`WILSON SONSINI GOODRICH & ROSATI
`701 Fifth Avenue, Suite 5100
`Seattle, WA 98104-7036
`Tel: (206) 883-2500
`Fax: (206) 883-2699
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`

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`Case 2:17-cv-00932-JLR Document 70 Filed 03/30/18 Page 2 of 3
`Case 2:17-cv-00932-JLR Document 70 Filed 03/30/18 Page 2 of 3
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`I declare that I, Celeste Ingalls, specialize in the service of civil process in foreign
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`countries, am a resident of Oregon, citizen of the United States, over the age of twenty-one, not a
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`party nor an attorney for any party in this action, and declare the following:
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`1.
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`2.
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`I am Director of Operations for Crowe Foreign Services; and
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`On March 20, 2018, I was instructed by members of TransPerfect Legal Solutions
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`to initiate the proper procedures to properly and formally effect service of process in Taiwan
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`upon CyWee Motion Group Ltd.; and
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`3.
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`Taiwan is not a signatory to any treaty, convention, or multilateral agreement for
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`the service of civil process; and
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`4.
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`I have successfully, on a frequent and regular basis for more than 22 years, facilitated
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`the formal service of process in Taiwan from various United States Federal and State Courts in
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`accordance with the proper procedures and documentation of letters rogatory; and
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`5.
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`I have lectured to state/county bar and other professional associations on the
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`mechanics and requirements of process service in foreign countries; and
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`6.
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`In accordance with Rule 4(h)(2) of the Federal Rules of Civil Procedure, service
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`upon a corporation ....... in a place not within any judicial district of the United States shall be by
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`any manner prescribed for individuals by subdivision (f) --except personal delivery as provided
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`in paragraph (2)(C)(i) thereof. In accordance with Rule 4(f)(2)(B), service shall be as directed
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`by the foreign authority in response to a letter rogatory or letter of request; and
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`7.
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`The United States Department of State in Washington, DC has designated the
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`American Institute in Taipei, Taiwan as the consular representative authorized to receive
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`requests for the service ofjudicial documents in Taiwan in response to a letter rogatory from the
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`United States Department of State and forward to the Taiwan judicial authorities for service; and
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`8.
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`In accordance with Rule 402 of the Taiwan Rules of Civil Procedure, only the
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`Taiwan District Court is authorized to serve foreign process in Taiwan; and
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`9.
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`Taiwan courts, as evidenced by a Taiwan supreme court ruling dated February 20,
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`2006, will not consider enforcement of a US. judgment unless all civil process procedures have
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`DECLARATION OF CELESTE INGALLS
`2:17-CV-00932-JLR
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`2
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`WILSON SONSINI GOODRICH & ROSATI
`701 Fiflh Avenue, Suite 5100
`Seattle, WA 98104-7036
`Tel: (206) 883-2500
`Fax: (206) 883-2699
`
`

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`Case 2:17-cv-00932-JLR Document 70 Filed 03/30/18 Page 3 of 3
`Case 2:17-cv-00932-JLR Document 70 Filed 03/30/18 Page 3 of 3
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`been validly accomplished through the Taiwan District Courts in accordance with Taiwan Civil
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`Rules; and
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`10.
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`The Taiwan District Courts require that all documents to be served, including the
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`signed letter rogatory request, must be translated into Chinese. This translation process will be
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`completed upon final court issuance of the letter rogatory request; and
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`11.
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`The letter rogatory request must be signed and sealed by a judge in the US. forum
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`court; and
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`12.
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`When the letter rogatory documents are prepared, signed and translated, and all
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`fees paid, the executed Letter Rogatory Request, Second Supplemental Summons, Notice of
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`Entry, Stipulation, Supplemental Summons, and Second Supplemental and Amended Complaint
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`in the above titled case, with Chinese translations thereof, shall be forwarded to the appropriate
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`division of the United States Department of State for transfer through the requisite diplomatic
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`channels for formal services upon CyWee Motion Group Ltd. by the Taiwan District Courts; and
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`13.
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`It has been my experience that service in Taiwan in response to a letter rogatory
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`takes a minimum of approximately six months to effect, dependent upon the location where the
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`service is to take place, but could take up to twelve months or more.
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`I declare under penalty of perjury pursuant to 28 U.S.C. § 1746 that the foregoing is true
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`and correct. Executed March 29, 2018, at Portland, Oregon.
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`Wéfuzm
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`Celeste Ingalls
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`p—a
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`KOOO\IO\UI-I>LBN
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`NNNNNNNNP—‘i—At—Ir—It—lh—dr—IHt—IH\lONUI-hbJNI-‘OKOOOQONUI-hWNI—‘O
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`DECLARATION OF CELESTE INGALLS
`2: 1 7-cv-OO932-JLR
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`3
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`WILSON SONSINI Goomuca & Rosm
`701 Fifth Avenue, Suite 5100
`Seattle, WA 98104-7036
`Tel: (206) 883-2500
`Fax: (206) 883-2699
`
`