IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

WSOU INVESTMENTS, LLC D/B/A 

BRAZOS LICENSING AND 

DEVELOPMENT, 

Plaintiff,

v. 

MICROSOFT CORPORATION, 

Defendant. 

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CIVIL ACTION NO. 6:20-cv-00454-ADA 

CIVIL ACTION NO. 6:20-cv-00457-ADA 

CIVIL ACTION NO. 6:20-cv-00460-ADA 

CIVIL ACTION NO. 6:20-cv-00461-ADA 

CIVIL ACTION NO. 6:20-cv-00463-ADA 

CIVIL ACTION NO. 6:20-cv-00464-ADA 

CIVIL ACTION NO. 6:20-cv-00465-ADA 

DECLARATION OF IRENE YANG IN SUPPORT OF DEFENDANT 

MICROSOFT CORPORATION’S MOTION FOR RECONSIDERATION OF ITS 

MOTION TO TRANSFER VENUE TO AUSTIN DIVISION 

Case 6:20-cv-00460-ADA Document 115 Filed 03/18/22 Page 1 of 4
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I, Irene Yang, declare as follows: 

1. I am an attorney with the law firm of Sidley Austin LLP, counsel for 

Defendant Microsoft Corporation (“Microsoft”) in this action. I submit this 

declaration in support of Microsoft’s Motion for Reconsideration of Its Motion to 

Transfer Venue to the Austin Division of the Western District of Texas in this 

litigation and the 6 other litigations filed by WSOU Investments, LLC (“WSOU”) 

against Microsoft on the same day. I have personal knowledge of the facts set 

forth in this declaration and, if called as a witness, could and would testify thereto. 

2. Attached hereto as Exhibit A is a true and correct copy of excerpts 

from the Deposition of Matt Hogan, taken September 23, 2021. The cited portions 

of the excerpts have been highlighted for ease of reference. 

3. Attached hereto as Exhibit B is a true and correct copy of Plaintiff’s 

Rule 26(a) Initial Disclosures, served March 24, 2021. 

4. Attached hereto as Exhibit C is a true and correct copy of Plaintiff’s 

First Supplemental Rule 26(a) Disclosures, served November 15, 2021. 

5. Attached hereto as Exhibit D is a true and correct copy of excerpts 

from the Deposition of Craig Etchegoyen, taken October 13, 2021. The cited 

portions of the excerpts have been highlighted for ease of reference. 

6. Attached hereto as Exhibit E is a true and correct copy of excerpts 

from the Deposition of Stuart Shanus, taken October 15, 2021. The cited portions 

of the excerpts have been highlighted for ease of reference. 

7. Attached hereto as Exhibit F is a true and correct copy of excerpts 

from the transcript of the telephonic discovery hearing held November 30, 2020. 

The cited portions of the excerpts have been highlighted for ease of reference. 

8. Attached hereto as Exhibit G is a true and correct copy of a list of 

non-stop flights to and from Waco from the website of Waco Regional Airport, last 

visited on March 14, 2022. 

Case 6:20-cv-00460-ADA Document 115 Filed 03/18/22 Page 2 of 4
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9. Attached hereto as Exhibit H is a true and correct copy of a list of 

non-stop flights from Austin from the website www.austintexas.gov, last visited on 

March 14, 2022. 

10. Attached hereto as Exhibit I is a true and correct copy of a Google 

Flights listing of available flights from Kailua-Kona, Hawaii to Waco, Texas, last 

visited on March 14, 2022. 

11. Attached hereto as Exhibit J is a true and correct copy of a Google 

Flights listing of available flights from Kailua-Kona, Hawaii to Austin, Texas, last 

visited on March 14, 2022. 

12. Attached hereto as Exhibit K.1 is a true and correct copy of 

Defendant’s Second Amended Initial Disclosures Pursuant to Fed. R. Civ. P. 

26(A)(1), Civil Action No. 6:20-cv-00454, served September 30, 2021. 

13. Attached hereto as Exhibit K.2 is a true and correct copy of 

Defendant’s Amended Initial Disclosures Pursuant to Fed. R. Civ. P. 26(A)(1), 

Civil Action No. 6:20-cv-00457, served August 30, 2021. 

14. Attached hereto as Exhibit K.3 is a true and correct copy of 

Defendant’s Amended Initial Disclosures Pursuant to Fed. R. Civ. P. 26(A)(1), 

Civil Action No. 6:20-cv-00460, served August 23, 2021. 

15. Attached hereto as Exhibit K.4 is a true and correct copy of 

Defendant’s Second Amended Initial Disclosures Pursuant to Fed. R. Civ. P. 

26(A)(1), Civil Action No. 6:20-cv-00461, served January 13, 2022. 

16. Attached hereto as Exhibit K.5 is a true and correct copy of 

Defendant’s Amended Initial Disclosures Pursuant to Fed. R. Civ. P. 26(A)(1), 

Civil Action No. 6:20-cv-00463, served August 30, 2021. 

17. Attached hereto as Exhibit K.6 is a true and correct copy of 

Defendant’s Third Amended Initial Disclosures Pursuant to Fed. R. Civ. P. 

26(A)(1), Civil Action No. 6:20-cv-00464, served March 15, 2022. 

Case 6:20-cv-00460-ADA Document 115 Filed 03/18/22 Page 3 of 4
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18. Attached hereto as Exhibit K.7 is a true and correct copy of 

Defendant’s First Amended Initial Disclosures Pursuant to Fed. R. Civ. P. 

26(A)(1), Civil Action No. 6:20-cv-00465, served September 30, 2021. 

I declare under penalty of perjury under the laws of the United States of America 

that the foregoing is true and correct. 

Executed on March 18, 2022 in San Francisco, California. 

 

 Irene Yang 

Case 6:20-cv-00460-ADA Document 115 Filed 03/18/22 Page 4 of 4