American Patents LLC v. Mediatek, Inc. et al

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

Thompson Declaration

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION AMERICAN PATENTS LLC, Plaintiff, v. CIVIL ACTION NO. 6:18-CV-339 MEDIATEK INC., ET AL., JURY TRIAL DEMANDED Defendants. DECLARATION OF LARRY D. THOMPSON, JR. 1. I am an attorney at the law firm of Antonelli, Harrington & Thompson LLP. I am counsel for American Patents LLC in this action. I respectfully submit this Declaration in support of American Patents' Response to Defendants' Submission of Protective Order. I have personal knowledge of the facts stated herein, and if called as a witness, could competently testify thereto. 2. American Patents' primary technical consultant is a firm called iRunway, which is based in Bangalore, India. Its website explains that it has a business model that revolves around consulting efforts related to patent litigation. By relying on the offset workday and lower cost of living in India, iRunway provides U.S. litigation teams with almost around-the-clock technical support at a much lower cost than purely U.S.-based advisors. See http://www.i- runway.com/technology-experts/about-us.html# (last accessed September 26, 2019). 3. iRunway has been retained by some of the nation's most prominent law firms. See http://www.i-runway.com/technology-research-clients/client-list.html# (listing clients such as Cooley, Cravath, and Susman Godfrey, among others) (last accessed September 26, 2019). 1 4. iRunway's website states, "We also have an ethical and legal obligation to protect the sensitive personal and business information of our clients. Our ISO 27001 certified information security systems and policies, designed by Ernst & Young, ensure confidentiality, integrity and 24/7 availability of all sensitive resources." See http://www.i- runway.com/technology-experts/about-us.html (last accessed September 26, 2019). I declare under penalty of perjury that the foregoing is true and correct. Executed on October 2, 2019 in Houston, Texas. /s/ Larry D. Thompson, Jr Larry D. Thompson, Jr. 2