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`Case 2:17-cv-00932-JLR Document 91 Filed 05/23/18 Page 1 of 3
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`THE HONORABLE JAMES L. ROBART
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`UNITED STATES DISTRICT COURT
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`WESTERN DISTRICT OF WASHINGTON
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`AT SEATTLE
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`CYWEE GROUP LTD.,
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`Plaintiffs,
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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 MATT BERKOWITZ
`IN SUPPORT OF
`STMICROELECTRONICS, INC.’S
`MOTION FOR SANCTIONS
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`HTC CORPORATION, and HTC AMERICA,
`INC.,
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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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`v.
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`BERKOWITZ DECLARATION IN SUPPORT OF
`STMICROELECTRONICS INC’S MOTION FOR SANCTIONS
`CASE NO.: 2:17-CV-00932-JLR
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`Shearman & Sterling LLP
`1460 El Camino Real
`Menlo Park, CA 94025
`Tel: 650-838-3737
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`Case 2:17-cv-00932-JLR Document 91 Filed 05/23/18 Page 2 of 3
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`I, Matt Berkowitz, declare as follows,
`1.
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`I am a partner at the law firm of Shearman & Sterling LLP (“Shearman”), counsel
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`for third party defendant STMicroelectronics, Inc. (“ST Inc.”). I am a member in good standing of
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`the Bar of the State of New York and the Bar of the State of California and have been admitted
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`pro hac vice in this above-referenced action. I make this declaration based on personal knowledge
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`and, if called as a witness, I could and would testify competently to the matters set forth herein. I
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`make this declaration in support of ST Inc.’s Motion for Sanctions in connection with the above-
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`captioned matter.
`2.
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`I am the partner at Shearman responsible for reviewing and approving all bills to
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`ST Inc. in connection with this matter. Thus far, my firm has billed ST Inc. $56,868.00 in fees,
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`and $483.06 in costs relating to Westlaw transactions, for a total of $57,351.06, in connection with
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`ST Inc.’s defense. The fees incurred cover time spent through the date of the Court’s Order, Dkt.
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`# 79, (i) analyzing the litigation and HTC’s third-party complaint; (ii) attempting to resolve the
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`matter without the need for motion practice (including a face-to-face meeting with HTC’s
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`counsel); (iii) drafting the motion to dismiss; and (iv) attending to miscellaneous case matters,
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`including general docket monitoring and analysis of the parties’ filings and contentions.
`3.
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`The fees incurred break down as follows:
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`Individual (Title)
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`Matt Berkowitz (Partner)
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`Joseph Purcell (Sr. Associate)
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`Shiina Akasaka (Sr. Paralegal)
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`Joel Dizon (E-Discovery Coordinator)
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`Hourly Rate
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`Hours
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`Total
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`$820
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`$600
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`$285
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`$240
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`48.9
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`21.2
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`11.6
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`3.1
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`$40,098.00
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`$12,720.00
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`$3,306.00
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`$744.00
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`4.
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`The above-referenced totals do not include fees and costs associated with time
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`spent in connection with ST Inc.’s motion for sanctions, which is ongoing, but which exceeds
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`BERKOWITZ DECLARATION IN SUPPORT OF
`STMICROELECTRONICS INC’S MOTION FOR SANCTIONS
`CASE NO.: 2:17-CV-00932-JLR
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`Shearman & Sterling LLP
`1460 El Camino Real
`Menlo Park, CA 94025
`Tel: 650-838-3737
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`Case 2:17-cv-00932-JLR Document 91 Filed 05/23/18 Page 3 of 3
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`$7,500 as of the date of this filing. That amount includes more than 7 hours of time that I have
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`spent at the above hourly rate and more than 4 hours spent by mid-level associate, Sonal Patel, at
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`$495/hr.
`5.
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`The above-referenced totals also do not include fees incurred by the law firm of
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`Lane Powell PC, which is also representing ST Inc. in this matter.
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`I declare under penalty of perjury under the laws of the United States that the foregoing is
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`true and correct.
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`Executed this 23 day of May, 2018, in Menlo Park, CA.
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`s/ Matt Berkowitz
` Matt Berkowitz
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`BERKOWITZ DECLARATION IN SUPPORT OF
`STMICROELECTRONICS INC’S MOTION FOR SANCTIONS
`CASE NO.: 2:17-CV-00932-JLR
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`Shearman & Sterling LLP
`1460 El Camino Real
`Menlo Park, CA 94025
`Tel: 650-838-3737
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