American Patents LLC v. Mediatek, Inc. et al

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

Declaration of Lai L. Yip

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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 LAI L. YIP IN SUPPORT OF SPECIALLY APPEARING DEFENDANTS LENOVO (SHANGHAI) ELECTRONICS TECHNOLOGY CO., LTD. AND LENOVO GROUP LTD.'S MOTION TO DISMISS FOR IMPROPER SERVICE OF PROCESS, LACK OF PERSONAL JURISDICTION, AND IMPROPER VENUE I, Lai L. Yip, declare as follows: 1. I am an attorney admitted pro hac vice to practice before this Court. I am a partner with Sheppard, Mullin, Richter & Hampton, LLP, attorneys for specially appearing defendants Lenovo (Shanghai) Electronics Technology Co., Ltd. and Lenovo Group Ltd. (the "Lenovo Defendants"). 2. I visited the webpage www.lenovocareers.com, on which I clicked "Search Jobs." This took me to the webpage http://www.lenovocareers.com/#search. This webpage contains a dropdown menu that defaults to "All Locations." When I clicked on that dropdown menu, I saw SMRH:489640469.1 -1- a list of countries and regions (e.g., states, cities, and districts in these countries). At my direction and under my supervision, my team counted up approximately 50 countries and 143 regions in this dropdown menu. I declare under penalty of perjury under the federal laws of the United States that the foregoing is true and correct. Executed on March 7, 2019, in San Francisco, California Lai L. Yip SMRH:489640469.1 -2- CERTIFICATE OF SERVICE I hereby certify that on March 7, 2019, a true and correct copy of the foregoing DECLARATION OF LAI L. YIP IN SUPPORT OF SPECIALLY APPEARING DEFENDANTS LENOVO (SHANGHAI) ELECTRONICS TECHNOLOGY CO., LTD. AND LENOVO GROUP LTD.'S MOTION TO DISMISS FOR IMPROPER SERVICE OF PROCESS, LACK OF PERSONAL JURISDICTION, AND IMPROPER VENUE 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. /s/ Lai L. Yip (Admitted Pro Hac Vice) Lai L. Yip SMRH:489640469.1 -3-