IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

IKORONGO TECHNOLOGY LLC and 

IKORONGO TEXAS LLC,

Plaintiffs,

v.

LG ELECTRONICS INC., and LG 

ELECTRONICS U.S.A., INC.,

Defendants.

Civil Action No. 6:20-cv-257-ADA

JURY TRIAL DEMANDED

DEFENDANTS’ OPPOSED MOTION TO TRANSFER TO THE NORTHERN 

DISTRICT OF CALIFORNIA UNDER 28 U.S.C. § 1404(a)

Case 6:20-cv-00257-ADA Document 27 Filed 09/11/20 Page 1 of 15
TABLE OF CONTENTS

Page

LG’S MOT. FOR TRANSFER -i- 6:19-cv-00355-ADA

TO NDCA OR AUSTIN

I. INTRODUCTION ............................................................................................................. 1

II. FACTUAL BACKGROUND............................................................................................ 1

A. Ikorongo’s Allegations Are Directed At Third-Party Applications....................... 1

B. Google is Located in the NDCA............................................................................ 2

C. Relevant LG Employees and Documents Are Not in This District....................... 3

D. AT&T Secure Family Was Researched, Designed, and Developed in the 

NDCA .................................................................................................................... 4

E. Named Inventors Are Located in the NDCA......................................................... 4

III. LEGAL STANDARD........................................................................................................ 4

IV. THIS CASE COULD HAVE BEEN FILED IN THE NDCA .......................................... 5

V. THE NDCA IS THE MOST CONVENIENT FORUM FOR THIS CASE ...................... 6

A. The Private Interest Factors Heavily Favor Transfer to the NDCA ...................... 6

1. The Relative Access to Sources of Proof................................................... 6

2. The Availability of Compulsory Process to Secure the Attendance 

of Witnesses............................................................................................... 7

3. The Convenience of Third-Party Witnesses and Party Witnesses 

Strongly Favors Transfer ........................................................................... 8

4. All Other Practical Problems That Make Trial of a Case Easy, 

Expeditious, and Inexpensive .................................................................. 10

B. The Public Interest Factors Favor Transfer ......................................................... 10

VI. CONCLUSION................................................................................................................ 10

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TABLE OF AUTHORITIES

Page(s)

LG’S MOT. FOR TRANSFER -ii- 6:19-cv-00355-ADA

TO NDCA OR AUSTIN

Cases

Action Indus., Inc. v. U.S. Fid. & Guar. Co.,

358 F.3d 337 (5th Cir. 2004) ...................................................................................................... 5

DataQuill, Ltd. v. Apple Inc.,

No. A-13-CA-706-SS, 2014 WL 2722201 (W.D. Tex. June 13, 2014) ..................................... 7

In re Adobe Inc.,

No. 2020-126, 2020 WL 4308164 (Fed. Cir. July 28, 2020)................................................ 9, 10

In re Genentech, Inc.,

566 F.3d 1338 (Fed. Cir. 2009) ......................................................................................... passim

In re Volkswagen AG,

371 F.3d 201 (5th Cir. 2004) (Volkswagen I)............................................................................. 5

In re Volkswagen of Am., Inc.,

545 F.3d 304 (5th Cir. 2008) (Volkswagen II)................................................................ 5, 6, 7, 8

Parus Holdings Inc. v. LG Elecs. Inc.,

No. 6:19-CV-00432-ADA, 2020 WL 4905809 (W.D. Tex. Aug. 20, 2020)...................... 1, 8, 9

Wet Sounds, Inc. v. Audio Formz, LLC,

No. A-17-CV-141-LY, 2017 WL 4547916 (W.D. Tex. Oct. 11, 2017)..................................... 9

XY, LLC v. Trans Ova Genetics, LC,

No. 16-CA-00447-RP, 2017 WL 5505340 (W.D. Tex. Apr. 5, 2017) ....................................... 6

Statutes

28 U.S.C. § 1391(c)(3).................................................................................................................... 5

28 U.S.C. § 1400(b)........................................................................................................................ 5

28 U.S.C. § 1404(a) ........................................................................................................................ 5

Rules

Fed. R. Civ. P. 45(c)(1)(A) ............................................................................................................. 7

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TO NDCA

I. INTRODUCTION

Pursuant to 28 U.S.C. § 1404(a), Defendants LG Electronics Inc. and LG Electronics 

U.S.A., Inc. (collectively, “LG”) seek transfer of this action to the Northern District of California 

(“NDCA”). The private and public interest factors courts deem most important—convenience for 

witnesses, particularly third-party witnesses, compulsory process for third parties, and the location 

of evidence—all weigh in favor of transfer. Indeed, this Court recently granted LG’s motion to 

transfer in Parus Holdings under similar circumstances. See Parus Holdings Inc. v. LG Elecs. 

Inc., No. 6:19-CV-00432-ADA, 2020 WL 4905809 (W.D. Tex. Aug. 20, 2020). 

Transfer to the NDCA is clearly more convenient. While Plaintiffs Ikorongo Technology 

LLC and Ikorongo Texas LLC (collectively, “Ikorongo”) allege infringement against smartphones 

sold by LG, Ikorongo’s infringement contentions are directed at functionality found in the Google 

Maps, Google+, Google Play Music, YouTube Music, and AT&T Secure Family applications 

(collectively, the “Accused Applications”) running on those smartphones. For three out of the five 

applications, the accused features were developed in the NDCA: Google Maps, Google+, and 

AT&T Secure Family. The accused features in Google Play Music and YouTube Music were 

primarily developed in New York City. None of the Accused Applications were developed in the 

Western District of Texas (“WDTX”). Moreover, two of the named inventors of the four asserted 

patents currently reside in the NDCA, and no named inventors or other third-party witnesses 

appear to be located in the WDTX. Because the location of the third parties and evidence in the 

NDCA strongly favor transfer, this action should be transferred to the NDCA.

II. FACTUAL BACKGROUND

A. Ikorongo’s Allegations Are Directed At Third-Party Applications

Ikorongo alleges that LG’s smartphones and tablets infringe four patents—U.S. Patent Nos. 

RE41,450 (the “’450 Patent”); RE45,543 (the “’543 Patent”); RE47,704 (the “’704 Patent”); and 

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8,874,554 (the “’554 Patent”) (collectively, “Asserted Patents”). The three reissue patents are 

directed to users sharing visited geographic location data with a group of other users using mobile 

devices. Am. Compl., ECF No. 2, Exs. F-H. The ’554 Patent is directed to providing locationbased media recommendations. Am. Compl., ECF No. 2, Ex. I. 

Ikorongo’s preliminary infringement contentions, served on August 8, 2020, make clear 

that its allegations rely on functionality found in the Accused Applications. See Lau Decl., Ex. 1

(Ikorongo Infringement Contentions Cover Pleading) at 1, 3-4, 6. Indeed, Ikorongo’s allegations 

concern devices “preloaded” with the Accused Applications. Id.

B. Google is Located in the NDCA

Third-party Google, LLC (“Google”) is a Delaware limited liability company with its 

principal place of business in Mountain View in the NDCA. Declaration of Daniel S. Friedland

in Support of Defendants’ Motion to Transfer (“Friedland Decl.”) ¶ 2. Google’s headquarters, 

which includes offices in Sunnyvale and San Francisco (collectively referred to as “Bay Area”), is 

the strategic center of Google’s business. Id. 

Google’s employees knowledgeable about the accused Google Maps and Google+ features 

are based in the NDCA. Id. ¶¶ 4-8. For example, the engineer who leads a team working on 

location sharing for Google Maps is based in Mountain View, along with her team members. Id.

¶ 5. Another engineer who leads a team working on Android location infrastructure and his team 

members are also based in Mountain View. Id. Additionally, the team of engineers that developed

and supported the accused Google+ features were located in Mountain View. Id. ¶¶ 7-8. Google 

is unaware of any employees located in the WDTX who have worked on the accused Google Maps 

and Google+ functionality. Id. ¶¶ 5, 8. 

Google’s employees knowledgeable about the accused Google Play Music and YouTube 

Music features are located primarily in New York City, with team members also located in Seattle 

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and Mountain View. Id. ¶¶ 9-10. For example, one engineer who has worked on the accused 

Google Play Music and YouTube Music features is currently based in Seattle, Washington, but 

belongs to a broader team of engineers, most of whom are based in New York City. Id. ¶ 10. 

Google is unaware of any employees who have worked on the accused Google Play Music and 

YouTube Music functionality and are located in the WDTX. Id.

C. Relevant LG Employees and Documents Are Not in This District

Defendant LG Electronics, Inc. (“LGEKR”) is a corporation founded under the laws of 

Korea with its principal place of business in Korea. Declaration of JuSeong Ryu in Support of 

Defendants’ Motion to Transfer (“Ryu Decl.”) ¶ 6. All of LGEKR’s design, engineering, and 

manufacturing work for the accused LG devices is done outside the United States, mostly in Korea. 

Id. LGEKR does not have offices in the United States, and therefore its technical documents are 

also located outside of the United States. Id. ¶ 14. 

Defendant LG Electronics U.S.A., Inc. (“LGEUS”) is a corporation founded under the laws 

of Delaware with its principal place of business in Englewood Cliffs, New Jersey. Id. ¶ 7. LGEUS 

has offices in Santa Clara and San Francisco in the NDCA, where it has about 120 employees, 

including employees responsible for LG’s relationship with third-parties such as Google as it 

relates to incorporation of the Accused Applications into LG products. Id. ¶ 16. For example, the 

LG team responsible for ensuring that LG’s devices, including the accused devices, properly run 

Android, are located in Santa Clara. Id. This team regularly communicates and interacts with 

Google personnel located in Google’s Mountain View headquarters. Id. LGEKR employees also 

regularly travel to LGEUS’s San Francisco Bay Area offices to coordinate with LGEUS and 

Google regarding incorporation of the Accused Applications into LG products. Id. ¶ 17.

No employees of any LG entity control the design and development of any features of the 

Accused Applications. Id. ¶ 8. Nor does any LG entity have any employees that modify any 

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aspect of the source code for the Accused Applications. Id. ¶ 9. LG has no non-public technical 

documents relating to the Accused Applications. Id. ¶ 10.

D. AT&T Secure Family Was Researched, Designed, and Developed in the 

NDCA

Based on publicly available information, it appears that AT&T’s Secure Family was 

researched, designed, and developed by third-party Location Labs at its headquarters in 

Emeryville, California within the NDCA. Lau Decl., Ex. 2 (Location Labs by Avast Blog); Ex 3

(Shanna Jan Resume); Ex. 4 (Location Labs Crunchbase Webpage). A team of approximately 30 

engineers at Location Labs researched, designed, and developed Secure Family. Lau Decl., Ex. 

2 (Location Labs by Avast Blog). Location Labs was later acquired by Avast Software s.r.o. 

(“Avast”). Lau Decl., Ex. 4 (Location Labs Crunchbase Webpage). Avast currently has four 

U.S. offices, two of which are in NDCA—Avast’s Silicon Valley and Emeryville offices. Lau 

Decl., Ex. 5 (Avast Contacts Webpage). Avast does not have any offices in Texas. Id. 

Moreover, although AT&T is headquartered in Dallas, Texas, it appears they did not develop 

Secure Family, as detailed above. Instead, the lead app developer for Secure Family is a 

Location Labs employee located in Merced, California. Lau Decl., Ex. 6 (Secure Family Lead 

LinkedIn Profile).

E. Named Inventors Are Located in the NDCA

There are six named inventors in the Asserted Patents. Two of them, Brady Bruce and 

Michael Mitchell, currently reside in the NDCA in San Francisco and Santa Cruz, California, 

respectively. Lau Decl. ¶ 8. None of the named inventors currently reside in or near WDTX. Id.

III. LEGAL STANDARD

Under 28 U.S.C. § 1404(a), “For the convenience of parties and witnesses, in the interest 

of justice, a district court may transfer any civil action to any other district or division where it 

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might have been brought . . . .” 28 U.S.C. § 1404(a). “The preliminary question under § 1404(a) 

is whether a civil action ‘might have been brought’ in the destination venue.” In re Volkswagen 

of Am., Inc., 545 F.3d 304, 312 (5th Cir. 2008) (Volkswagen II) (quoting 28 U.S.C. § 1404(a)). 

“The determination of ‘convenience’ turns on a number of public and private interest 

factors, none of which can be said to be of dispositive weight.” Action Indus., Inc. v. U.S. Fid. & 

Guar. Co., 358 F.3d 337, 340 (5th Cir. 2004). The private factors include: “(1) the relative ease 

of access to sources of proof; (2) the availability of compulsory process to secure the attendance 

of witnesses; (3) the cost of attendance for willing witnesses; and (4) all other practical problems 

that make trial of a case easy, expeditious and inexpensive.” In re Volkswagen AG, 371 F.3d 201, 

203 (5th Cir. 2004) (Volkswagen I). The public factors include: “(1) the administrative difficulties 

flowing from court congestion; (2) the local interest in having localized interests decided at home; 

(3) the familiarity of the forum with the law that will govern the case; and (4) the avoidance of 

unnecessary problems of conflict of laws of the application of foreign law.” Id.

IV. THIS CASE COULD HAVE BEEN FILED IN THE NDCA

A patent infringement case may be brought in “the judicial district where the defendant 

resides, or where the defendant has committed acts of infringement and has a regular and 

established place of business.” 28 U.S.C. § 1400(b). LGEUS has offices in the NDCA with over 

120 employees. Additionally, LGEKR is a foreign corporation, so venue is proper in any 

district, including the NDCA,. 28 U.S.C. § 1391(c)(3). And because LGEKR employees 

regularly travel to the NDCA, the NDCA has personal jurisdiction over LGEKR. Thus, these 

cases could have been brought in the NDCA. 

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V. THE NDCA IS THE MOST CONVENIENT FORUM FOR THIS CASE

A. The Private Interest Factors Heavily Favor Transfer to the NDCA

1. The Relative Access to Sources of Proof

“[T]he sources of proof requirement is a meaningful factor” in the transfer analysis. In re 

Volkswagen of Am., Inc., 545 F.3d 304, 316 (5th Cir. 2008) (Volkswagen II). To determine the 

ease of access to sources of proof, the Court should look at “the location where the allegedly 

infringing products were researched, designed, developed and tested.” XY, LLC v. Trans Ova 

Genetics, LC, No. 16-CA-00447-RP, 2017 WL 5505340, at *13 (W.D. Tex. Apr. 5, 2017).

This factor heavily favors transfer because the greatest volume of evidence is in the NDCA 

with Google and other key third-parties. As discussed in Section II.A above, Ikorongo’s 

infringement allegations focus on features in the Accused Applications. A significant number of 

the development activities related to the accused features in Google Maps and Google+ occurred 

at Google’s Mountain View headquarters. Friedland Decl. ¶¶ 4-8. And nearly all the documents

that relate to the development or operation of these applications, including highly confidential 

proprietary source code, are either physically present in or electronically accessible from Google’s

offices within the NDCA. Id. ¶¶ 4, 7. In addition, based on publicly available information, it 

appears that Secure Family was researched, designed, and developed by third-party Location Labs 

from its Emeryville, California headquarters. See Section II.D, supra. Secure Family witnesses 

and documents are thus also likely to be in the NDCA. While some witnesses for Google Play 

Music and YouTube Music are in Seattle and New York, none are in the WDTX. Friedland Decl. 

¶¶ 9-10.

Moreover, “[i]n patent infringement cases, the bulk of the relevant evidence usually comes 

from the accused infringer.” In re Genentech, Inc., 566 F.3d 1338, 1345 (Fed. Cir. 2009). LG’s 

relevant witnesses are located in the NDCA, as discussed in detail in Section II.C. Although 

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LGEUS is headquartered in New Jersey, LGEUS’s employees that are responsible for LG’s 

relationship with third-parties like Google as it relates to incorporation of the Accused 

Applications into LG products are located in the NDCA. Ryu Decl. ¶ 16. 

And while LG has offices in Austin, the relevant inquiry is whether it has a presence that 

is related to the litigation. See DataQuill, Ltd. v. Apple Inc., No. A-13-CA-706-SS, 2014 WL 

2722201, at *5 (W.D. Tex. June 13, 2014) (granting transfer from the WDTX to the NDCA 

because “[t]here is no dispute [defendant] has a presence in this district, but that presence is 

unrelated to this litigation”). None of LG’s employees with responsibilities for the accused 

functionality in the Accused Applications are located in Austin. Ryu Decl. ¶¶ 8-10. Defendants 

are also unaware of any Austin-based AT&T or Google employees involved in the research or 

design of the Accused Applications.

While Ikorongo Texas LLC has not yet identified any relevant evidence in WDTX, any 

such limited evidence is greatly outweighed by the relevant evidence located in the NDCA. See

In re Genentech, Inc., 566 F.3d at 1345. The relative ease of access of proof heavily favors 

transfer.

2. The Availability of Compulsory Process to Secure the Attendance of 

Witnesses

When deciding a transfer motion, the Court considers the availability of compulsory 

process to secure the attendance of witnesses, particularly non-party witnesses whose attendance 

may need to be secured by a court order. In re Volkswagen of Am., Inc., 545 F.3d 304, 316 (5th 

Cir. 2008) (Volkswagen II). A court may subpoena a witness to attend trial only “within 100 miles 

of where the person resides, is employed, or regularly transacts business in person.” Fed. R. Civ. 

P. 45(c)(1)(A).

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The availability of compulsory process weighs heavily in favor of transfer. As discussed 

above in connection with the first factor, the vast majority of third-party witnesses who may testify 

reside in the NDCA. No identifiable witnesses reside in WDTX or are subject to the Court’s 

subpoena power. Accordingly, this factor weighs heavily in favor of a transfer. 

3. The Convenience of Third-Party Witnesses and Party Witnesses 

Strongly Favors Transfer

“The convenience of witnesses is the single most important factor in the transfer analysis.” 

Parus Holdings Inc. v. LG Elecs. Inc., No. 6:19-CV-00432-ADA, 2020 WL 4905809, at *5 (W.D. 

Tex. Aug. 20, 2020) (citing In re Genentech, Inc., 566 F.3d at 1342). “The Court gives the 

convenience of party witnesses little weight.” Id.

The convenience of witnesses weighs strongly in favor of transfer to NDCA. As detailed 

in Section II.B, the majority of key third-party witnesses reside in the NDCA, Seattle, and New 

York, while none reside in or even near this District. If this case remains in WDTX, those 

witnesses will need to fly and/or drive to Waco, Texas for trial and any hearings that require their 

testimony. Flying multiple employees to Waco and providing food, lodging, and transportation is 

unduly expensive. These inconveniences are easily avoided by transferring this action to the 

NDCA, where many third-party witnesses can drive less than 50 miles to any court proceeding 

and return home afterwards. Lau Decl. ¶ 7.

The lost productivity and interruption to the witnesses’ daily and personal lives due to the 

time they will spend traveling also greatly weighs in favor of transfer. See In re Volkswagen of 

Am., 545 F.3d at 317 (“Witnesses not only suffer monetary costs, but also the personal costs 

associated with being away from work, family, and community.”). The shortest commercial flights 

to Waco from the Bay Area require around 5 hours and 15 minutes of air travel (including a one 

hour layover in Dallas), not to mention time spent getting to, from, and waiting at the airport. As 

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this Court has recognized, “the task of scheduling fact witnesses so as to minimize the time when 

they are removed from their regular work or home responsibilities gets increasingly difficult and 

complicated when the travel time from their home or work site to the court facility is five or six 

hours one-way as opposed to 30 minutes or an hour.” Wet Sounds, Inc. v. Audio Formz, LLC, No. 

A-17-CV-141-LY, 2017 WL 4547916, at *3 (W.D. Tex. Oct. 11, 2017), report and 

recommendation adopted, No. 1:17-CV-141-LY, 2018 WL 1219248 (W.D. Tex. Jan. 22, 2018). 

For any third-party witnesses that do not reside in the NDCA, adding flight time to the Bay 

Area is insignificant when compared to the cost of requiring Google and other third-party inventors 

to travel to Waco. These witnesses will already need food, lodging, and transportation in Waco 

because none reside in WDTX. Furthermore, the Federal Circuit has recently explained that “[t]he 

comparison between the transferor and transferee forums is not altered by the presence of other 

witnesses and documents in places outside both forums.” In re Adobe Inc., No. 2020-126, 2020 

WL 4308164, at *3 (Fed. Cir. July 28, 2020). Accordingly, any argument that other third parties 

who live outside of WDTX may be inconvenienced by a transfer does not withstand scrutiny. 

Moreover, LGEUS’s relevant party witnesses reside in the NDCA. It is also much more 

convenient for LGEKR Korea-based witnesses to travel to the Bay Area than to Waco, Texas, 

which requires over 17 hours of travel and multiple flights. Lau Decl. ¶¶ 5-6. While Waco may 

be more convenient for Ikorongo, it is improper for a court to use “its central location as a 

consideration in the absence of witnesses within the plaintiff’s choice of venue.” In re Genentech, 

Inc., 566 F.3d at 1344. This factor weighs in favor of transfer. Parus Holdings Inc., 2020 WL 

4905809, at *6 (W.D. Tex. Aug. 20, 2020).

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4. All Other Practical Problems That Make Trial of a Case Easy, 

Expeditious, and Inexpensive

There are no practical problems associated with transfer. This case is in its infancy. The 

Markman hearing will not occur for five months, on February 5, 2021. Thus, transfer at this point 

would not cause delays. This factor is neutral.

B. The Public Interest Factors Favor Transfer

The public interest factors also weigh in favor of transfer. NDCA has a strong local 

interest in this dispute: LG integrates the Accused Applications into its products in the NDCA, 

and three of the Accused Applications, Google Maps, Google+, and AT&T Secure Family were 

developed in the NDCA. By contrast, the WDTX has little local interest in this dispute. Public 

records indicate Ikorongo Texas LLC was just recently incorporated in Texas on February 26, 

2020, only weeks before it filed suit against LG. Lau Decl., Ex. 13. And the Amended 

Complaint provides the same North Carolina address for both Ikorongo Technology LLC and 

Ikorongo Texas, LLC, indicating that neither entity, including Ikorongo Texas, LLC, is based in 

the WDTX. Am. Compl., ECF No. 2 at ¶¶ 1-2. Moreover, although this Court may be able to 

try the case earlier than a court in the NDCA, “time to trial appears to be the most speculative” of 

the factors in the transfer analysis. In re Genentech, Inc., 566 F.3d 1338, 1347 (Fed. Cir. 2009); 

see also In re Adobe Inc., No. 2020-126, 2020 WL 4308164, at *3 (Fed. Cir. July 28, 2020)

(“Nothing about [a] court’s general ability to set a schedule directly speaks to that issue.”). The 

familiarity with governing law and conflict of laws factors are neutral as both NDCA and this 

District are familiar with, and will apply, federal patent law.

VI. CONCLUSION

For the foregoing reasons, LG respectfully requests the Court transfer this case to NDCA.

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Dated: September 11, 2020 /s/ J. Mark Mann

J. Mark Mann

State Bar No. 12926150

Email: Mark@themannfirm.com

G. Blake Thompson

State Bar No. 24042033

Email: Blake@themannfirm.com

MANN TINDEL THOMPSON

300 West Main Street

Henderson, Texas 75652

Telephone: (903) 657-8540

Facsimile: (903) 657-6003

Darin W. Snyder (Pro Hac Vice)

dsnyder@omm.com

David S. Almeling (Pro Hac Vice)

dalmeling@omm.com

O’MELVENY & MYERS LLP

Two Embarcadero Center

28th Floor

San Francisco, CA 94111

Telephone: 415-984-8700

Facsimile: 415-984-8701

Jeffrey Lau

jeffreylau@omm.com

O’MELVENY & MYERS LLP

400 South Hope Street

18th Floor

Los Angeles, CA 90071

Telephone: 213-430-6000

Attorneys for Defendants LG Electronics 

Inc. and LG Electronics U.S.A., Inc.

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CERTIFICATE OF CONFERENCE

Pursuant to Local Rule CV-7(i), counsel for LG conferred with counsel for Ikorongo on 

September 9, 2020, in a good-faith effort to resolve the matter presented herein and counsel for 

Ikorongo stated that it opposed the motion.

/s/ J. Mark Mann

 Mark Mann

CERTIFICATE OF SERVICE

Pursuant to the Federal Rules of Civil Procedure and Local Rule CV-5, I hereby certify 

that, on September 11, 2020, all counsel of record who have appeared in this case are being served 

with a copy of the foregoing via the Court’s CM/ECF system.

/s/ J. Mark Mann

 Mark Mann

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