American Patents LLC v. Mediatek, Inc. et al

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

Supplemental Declaration of Kurt Cranor

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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. SUPPLEMENTAL DECLARATION OF KURT CRANOR IN SUPPORT OF SPECIALLY APPEARING DEFENDANTS LENOVO (SHANGHAI) ELECTRONICS TECHNOLOGY CO ., LTD. AND LENOVO GROUP LTD. ' S REPLY IN SUPPORT OF MOTION TO DISMISS FOR IMPROPER SERVICE OF PROCESS, LACK OF PERSONAL JURISDICTION, AND IMPROPER VENUE 1, Kurt Cranor, declare as follows: 1. I am employed by Lenovo (United States) Inc. ("LenovoU.S.") in the position of Executive Director, North America Chief Financial Officer. I submit this supplemental declaration in support of the Motion to Dismiss for Improper Service of Process, Lack of Personal Jurisdiction, and Improper Venue filed by specially appearing Defendants Lenovo Group Limited ("LOL") and Lenovo (Shanghai) Electronics Technology Co ., Limited ("Lenovo Shanghai ') . I make the following statements of my own personal knowledge and would and could testify thereto if sworn as a witness at trial. SMRH: 489245721 - 1 2. I have reviewed Exhibit I to the Declaration of Larry D. Thompson, Jr ., which appears to be a printout from Import Genius, www. importgenius. com, showing Lenovo Shanghai as the " SHIPPER " for various products. While there are entries under " PRODUCT IL reare UIT DESCRIPTION " referring to " TABLE " in Exhibit I, it is my understanding that those descriptions refer to computer tables, not tablets. 3. The webpage https: / / www. lenovo. com / us / en / lenovo / locations / identifies several " Operational Centers, " one of which is at the address of 1009 Think Place, Morrisville, North Carolina 27560. This operational center in Morrisville is leased and operated by LenovoU.S. It is owned by an unrelated third - party. Dia Ire 4. Kirk Skaugen, Laura Quatela, and Matthew Zielinski are employees of LenovoU.S. only, not of LGL, Lenovo Shanghai, or any other Lenovo entity. LenovoU.S., LGL, and Lenovo Shanghai do not employ any of the same individuals. I declare under penalty of perjury under the federal laws of the United States that the foregoing is true and correct. Executed on March 5, 2019, in Morrisville, North Carolina. Dust Canon Kurt Cranor SMRH: 489245721 CERTIFICATE OF SERVICE I hereby certify that on March 5, 2019, a true and correct copy of the foregoing SUPPLEMENTAL DECLARATION OF KURT CRANOR 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 regularU.S. Mail. Parties may access this filing through the Court's electronic filing system. / s / Lai L. Yip (Pro Hac Vice Pending) Lai L. Yip SMRH: 489245721