UNITED STATES DISTRICT COURT 

FOR THE SOUTHERN DISTRICT OF FLORIDA 

MIAMI DIVISION 

DECURTIS LLC, 

 Plaintiff, 

v. 

CARNIVAL CORPORATION, 

 Defendant. 

 

CARNIVAL CORPORATION, 

 Plaintiff, 

v. 

DECURTIS CORPORATION and 

DECURTIS LLC, 

 Defendants. 

 

Civil Action No. 20-22945-Civ-Scola 

Civil Action No. 20-21547-Civ-Scola 

 

DECLARATION OF ANDREW C. NORDAHL 

 I, Andrew C. Nordahl, declare and state as follows: 

1. I am partner at the law firm Freeborn & Peters, LLP, represent DeCurtis LLC and 

DeCurtis Corporation in this action and submit this declaration in support of DeCurtis’s briefs in 

opposition to Carnival’s summary judgment and Daubert motions. 

2. Attached are true and correct copies of the following exhibits: 

Exhibit 1. --- U.S. Patent 10,045,184.

Exhibit 2. --- U.S. Patent 10,049,516.

Exhibit 3. --- U.S. Patent 10,157,514.

Exhibit 4. --- Excerpts from the transcript of the April 14, 2022 deposition of Erik de 

la Iglesia. 

Exhibit 5. --- CARNIVAL00070934, along with a printout of the metadata associated 

with this document, which was produced by Carnival in this litigation. 

Exhibit 6. --- Excerpts from the transcript of the January 12, 2022 deposition of Glenn 

Curtis. 

Exhibit 7. --- CARNIVAL00422177, which was produced by Carnival in this 

litigation. 

Case 1:20-cv-22945-RNS Document 302-1 Entered on FLSD Docket 05/10/2022 Page 1 of 5
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Exhibit 8. --- Excerpts from the transcript of the September 2, 2021 deposition of 

Patrick Shea. 

Exhibit 9. --- ASSAABLOY0001125, which was produced by Assa Abloy in this 

litigation. 

Exhibit 10. --- DeCurtis_00242858, which was produced by DeCurtis in this litigation.

Exhibit 11. --- CARNIVAL00125646, which was produced by Carnival in this 

litigation. 

Exhibit 12. --- CARNIVAL00124827, which was produced by Carnival in this 

litigation. 

Exhibit 13. --- Excerpts from the transcript (volume 2) of the January 18, 2022 

deposition of John Padgett 

Exhibit 14. --- a document beginning with Bates number DeCurtis_00241867, which 

was produced by DeCurtis in this litigation

Exhibit 15. --- a document beginning with Bates number DeCurtis_00242071, which 

was produced by DeCurtis in this litigation. 

Exhibit 16. --- excerpts from the transcript of the January 7, 2022 deposition of 

Michael Jungen. 

Exhibit 17. --- excerpts from the transcript (volume 2) of the January 14, 2022 

deposition of Douglas Steele. 

Exhibit 18. --- excerpts from the transcript (volume 1) of the January 13, 2022 

deposition of Douglas Steele. 

Exhibit 19. --- a document beginning with Bates number DeCurtis_01459616, which 

was produced by DeCurtis in this litigation. 

Exhibit 20. --- excerpts from the transcript (volume 1) of the February 3, 2022 

deposition of David DeCurtis. 

Exhibit 21. --- excerpts from the transcript of the December 21, 2021 deposition of 

Assa Abloy corporate representative Jon Engebretsen. 

Exhibit 22. --- a document beginning with Bates number ASSAABLOY0001102, 

which was produced by Assa Abloy in this litigation. 

Exhibit 23. --- a document beginning with Bates number DeCurtis_00157450, which 

was produced by DeCurtis in this litigation. 

Exhibit 24. --- excerpts from the transcript (volume 1) of the January 17, 2022 

deposition of John Padgett. 

Exhibit 25. --- a document beginning with Bates number DeCurtis_00157407, which 

was produced by DeCurtis in this litigation

Exhibit 26. --- a document beginning with Bates number DeCurtis_02005673, which 

was produced by DeCurtis in this litigation. 

Exhibit 27. --- excerpts from the transcript (volume 2) of the February 4, 2022 

deposition of David DeCurtis. 

Exhibit 28. --- a compilation of documents DeCurtis produced in this litigation, starting 

at the following Bates numbers: DeCurtis_00157332, 

DeCurtis_00157333, DeCurtis_00157352, DeCurtis_00157405, 

DeCurtis_00157407, DeCurtis_00157409, DeCurtis_00157426. 

Exhibit 29. --- excerpts from the transcript of the January 28, 2022 deposition of Kyle 

Prestenback. 

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Exhibit 30. --- excerpts from the transcript of the February 1, 2022 deposition of 

Richard Criado. 

Exhibit 31. --- excerpts from the transcript of the January 25, 2022 deposition of Adam 

Leonards. 

Exhibit 32. --- excerpts from the transcript of the January 19, 2022 deposition of 

Patrick Mendiuk. 

Exhibit 33. --- excerpts from the transcript of the November 1, 2021 deposition of 

Sander Lam. 

Exhibit 34. --- excerpts from the transcript of the December 15, 2021 deposition of 

Stephen Becker. 

Exhibit 35. --- a document beginning with Bates number DeCurtis_00157427, which 

was produced by DeCurtis in this litigation. 

Exhibit 36. --- a document beginning with Bates number CARNIVAL00000489, which 

was produced by Carnival in this litigation

Exhibit 37. --- a document beginning with Bates number DeCurtis_00157428, which 

was produced by DeCurtis in this litigation. 

Exhibit 38. --- U.S. Patent 10,037,642. 

Exhibit 39. --- U.S. Patent 10,304,271.

Exhibit 40. --- U.S. Patent 10,045,184 

Exhibit 41. --- DeCurtis Responses to Carnival's Second Set of Interrogatories [Nos. 

13-19] dated 03/09/2021 

Exhibit 42. --- Carnival Records Management Program - CARNIVAL00422177 

Exhibit 43. --- Mary Coleman Report dated 03/01/2022 

Exhibit 44. --- Mary Coleman Rebuttal Report dated 03/31/2022 

Exhibit 45. --- Dr. Matthew Shoemake Expert Report dated 03/01/2022 

Exhibit 46. --- Dr. Matthew Shoemake Expert Rebuttal Report dated 03/31/2022 

Exhibit 47. --- Nicholas Godici Expert Report 

Exhibit 48. --- Lynde Report dated 03/01/2022 

Exhibit 49. --- Lynde Rebuttal Report dated 03/31/2022 

Exhibit 50. --- Markus Jakobsson Rebuttal Report dated 03/31/2022 

Exhibit 51. --- David DeCurtis Deposition Transcript Vol. 1 

Exhibit 52. --- David DeCurtis Deposition Transcript Vol. 2 

Exhibit 53. --- John Padgett Deposition Transcript Vol. 1 

Exhibit 54. --- John Padgett Deposition Transcript Vol. 2 

Exhibit 55. --- Derek Fournier Deposition Transcript Vol. 1 

Exhibit 56. --- Derek Fournier Deposition Transcript Vol. 2 

Exhibit 57. --- Arnold Donald Deposition Transcript 

Exhibit 58. --- Glenn Curtis Deposition Transcript 

Exhibit 59. --- Lynde Deposition Transcript 

Exhibit 60. --- Douglas Steele Deposition Transcript Vol. 2 

Exhibit 61. --- Kyle Prestenback Deposition Transcript 

Exhibit 62. --- Richard Criado Deposition Transcript 

Exhibit 63. --- Adam Leonards Deposition Transcript 

Exhibit 64. --- Patrick Mendiuk Deposition Transcript 

Exhibit 65. --- Sander Lam Deposition Transcript 

Case 1:20-cv-22945-RNS Document 302-1 Entered on FLSD Docket 05/10/2022 Page 3 of 5
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Exhibit 66. --- Stephen Becker Deposition Transcript 

Exhibit 67. --- Michael Jungen Deposition Transcript 

Exhibit 68. --- Joseph Carino Deposition Transcript 

Exhibit 69. --- Andy Howard Deposition Transcript 

Exhibit 70. --- Patrick Shea Deposition Transcript (Carnival 30(b)(6)) 

Exhibit 71. --- DeCurtis_01474520 

Exhibit 72. --- DeCurtis_01633169 

Exhibit 73. --- 1-17-17 Carnival email chain_CARNIVAL00730697 

Exhibit 74. --- 1-5-17 Carnival Press Release_CARNIVAL00014898 

Exhibit 75. --- 2-5-20 Email between NCl and DeCurtis attaching Carnival's 1-29-20 

Letter_DeCurtis_01703003-10 

Exhibit 76. --- 2-5-20 Email re first review Carnival's 01-29-20 letter_NCL-004571 

Exhibit 77. --- 6-29-20 Evercore Study_CARNIVAL00753743 

Exhibit 78. --- 8-5-20 Meeting Notes_DeCurtis_01994948 

Exhibit 79. --- DeCurtis_01474502 

Exhibit 80. --- DeCurtis_01945577-5795 

Exhibit 81. --- DeCurtis_01986986 

Exhibit 82. --- Master License and Services Agreement_DeCurtis_00172207-2262 

Exhibit 83. --- 1-29-20 Letter to NCL_CARNIVAL00124886 

Exhibit 84. --- 2-04-20 Letter to Virgin_CARNIVAL00124884 

Exhibit 85. --- SeaCoin_JP_CC_00000175 

Exhibit 86. --- CARNIVAL00000489 

Exhibit 87. --- DeCurtis_01459616 

Exhibit 88. --- DeCurtis_00157407 

Exhibit 89. --- DeCurtis_00157428 

Exhibit 90. --- DeCurtis_02005673 

Exhibit 91. --- DeCurtis_00241867 

Exhibit 92. --- DeCurtis_00242071 

Exhibit 93. --- DeCurtis_00157450 

Exhibit 94. --- DeCurtis_00157332 

Exhibit 95. --- DeCurtis_00157333 

Exhibit 96. --- DeCurtis_00157352 

Exhibit 97. --- DeCurtis_00157405 

Exhibit 98. --- DeCurtis_00157426 

Exhibit 99. --- DeCurtis_01946098-151 

Exhibit 100. --- DeCurtis_00242858 

Exhibit 101. --- DeCurtis_01474525 

Exhibit 102. --- DeCurtis_01489120 

Exhibit 103. --- CARNIVAL 00375784-850 

Exhibit 104. --- CARNIVAL 00126750-784 

Exhibit 105. --- CARNIVAL00126764 

Exhibit 106. --- CARNIVAL 00126775 

Exhibit 107. --- CARNIVAL 00000384-423 

Exhibit 108. --- CARNIVAL00070934 

Exhibit 109. --- CARNIVAL00525876 

Case 1:20-cv-22945-RNS Document 302-1 Entered on FLSD Docket 05/10/2022 Page 4 of 5
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Exhibit 110. --- ASSAABLOY0001125 

Exhibit 111. --- 2019 Executive Business Update and July 2019 Company 

Overview_DeCurtis_01733587 

Exhibit 112 --- 6-11-19 Due Diligence Findings_Decurtis_01474520 

Exhibit 113. --- April 2014, an email to Mr. Padgett subject line “BLE beacon,” 

(DeCurtis_02005673) 

Exhibit 114. --- Q4 2020 Disclosure 

Exhibit 115. --- 12/13/2019 email between NCL and DeCurtis 

Exhibit 116. --- (2/4/2019 email between NCL and DeCurtis. 

 Pursuant to 28 U.S. Code § 1746 (2), I declare under penalty of perjury that the foregoing 

is true and correct. Executed on this 9th day of May, 2022 in Chicago, Illinois. 

 /s/ Andrew C. Nordahl 

 

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