American Patents LLC v. Mediatek, Inc. et al

Western District of Texas, txwd-6:2018-cv-00339

Declaration of Kurt Cranor

Interested in this case?

Current View

Full Text

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION AMERICAN PATENTS LLC, CIVIL ACTION NO. 6:18-CV-339-ADA Plaintiff, V. MEDIATEK INC., MEDIATEK USA INC., BROADCOM PTE. LTD., BROADCOM CORPORATION, LENOVO (SHANGHAI) ELECTRONICS TECHNOLOGY CO. LTD., LENOVO GROUP, LTD., NXP SEMICONDUCTORS N.V., NXP B.V., NXP USA, INC., QUALCOMM INCORPORATED and QUALCOMM TECHNOLOGIES, INC., Defendants. DECLARATION OF KURT CRANOR I, Kurt Cranor, declare as follows: 1. I am employed by Lenovo (United States), Inc. in the position of Executive Director, North America Chief Financial Officer. I make the following statements of my own personal knowledge and would and could testify thereto if sworn as a witness at trial. 2. Lenovo Group Limited is a holding company incorporated in China, with its principal place of business in Hong Kong. Lenovo (Shanghai) Electronics Technology Co. Limited is incorporated in China with its principal place of business in Shanghai, China. 3. Lenovo (United States), Inc. is an affiliate of Lenovo Group Limited and Lenovo (Shanghai) Electronics Technology Co. Limited (collectively, the "Chinese entities"). Lenovo SMRH:489053017 -1- (United States), Inc. is a Delaware corporation with its principal place of business in Morrisville, North Carolina. 4. The Chinese entities have no employees, offices, or property anywhere in the United States. Neither has authorized anyone in the United States to accept service of process on its behalf. The Chinese entities do not manufacture, sell, offer to sell, or distribute the accused products in the United States. They do not import or ship the accused products into the United States. Lenovo (United States), Inc. is responsible for all U.S. activities related to the accused products, including importing, pricing, and selling the accused products in the United States. I declare under penalty of perjury under the federal laws of the United States that the foregoing is true and correct. Executed on January~' 2019, in Morrisville, North Carolina. Kurt Cranor SMRH:489053017 -2- CERTIFICATE OF SERVICE I hereby certify that on January 31, 2019, a true and correct copy of the foregoing DECLARATION OF KURT CRANOR was filed electronically. Notice of this filing will be sent by operation of the Court's electronic filing system to all parties indicated on the electronic filing receipt. All other parties will be served by regular U.S. Mail. Parties may access this filing through the Court's electronic filing system. Isl Lai L. Yip (Admitted Pro Hac Vice) Lai L. Yip SMRH:489053017 -3-