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.

DELL TECHNOLOGIES INC., DELL INC., 

EMC CORPORATION, AND VMWARE, 

INC.,

Defendants.

Case No. 6:20-cv-00480-ADA

Case No. 6:20-cv-00481-ADA

Case No. 6:20-cv-00485-ADA

Case No. 6:20-cv-00486-ADA

JURY TRIAL DEMANDED

DECLARATION OF JAYSEN S. CHUNG IN SUPPORT OF

DEFENDANTS’ RESPONSIVE CLAIM CONSTRUCTION BRIEF

REGARDING U.S. PATENT NOS. 7,092,360; 7,539,133; 7,636,309; AND 9,164,800

Case 6:20-cv-00480-ADA Document 82-2 Filed 03/17/21 Page 1 of 4
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I, Jaysen S. Chung, declare as follows:

1. I am an attorney permitted to practice law before this Court pro hac vice and am 

licensed to practice law in California. I am an associate attorney with the law firm of Gibson, 

Dunn & Crutcher LLP and counsel of record for Defendants Dell Technologies Inc., Dell Inc., 

EMC Corporation, and VMware, Inc. in the above-captioned action. I have personal knowledge 

and/or am directly informed of the matters stated below and, if called, would testify to them under 

oath.

2. Attached here as Exhibit 1 are excerpts from the file history of U.S. Patent No. 

7,092,360 (“the ’360 patent”), specifically from the application for patent filed on December 28, 

2001. These excerpts were retrieved from the United States Patent Office’s website 

(https://portal.uspto.gov/pair/PublicPair).

3. Attached here as Exhibit 2 are excerpts from the file history of the ’360 patent, 

specifically from an amendment filed on May 18, 2006. These excerpts were retrieved from the 

United States Patent Office’s website (https://portal.uspto.gov/pair/PublicPair).

4. Attached here as Exhibit 3 are excerpts from the file history of the ’360 patent

dated June 5, 2006, including a Notice of Allowability, an Examiner-Initiated Interview Summary, 

and a Claim Index. These excerpts were retrieved from the United States Patent Office’s website 

(https://portal.uspto.gov/pair/PublicPair).

5. Attached here as Exhibit 4 is Defendants’ Preliminary Identification of Claim 

Terms for Construction dated January 6, 2021.

6. Attached here as Exhibit 5 is an email chain including an email from me to 

Plaintiff’s counsel Ryan Loveless dated February 8, 2021, which identifies claim construction 

disputes (the “February 8 Email”).

Case 6:20-cv-00480-ADA Document 82-2 Filed 03/17/21 Page 2 of 4
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7. Attached here as Exhibit 6 is a chart identifying Defendants’ Narrowed List of 

Terms of Construction, which was attached to the February 8 Email.

8. Attached here as Exhibit 7 is a PDF print out of the first tab of the spreadsheet 

entitled “Claim Construction Summaries,” which was submitted to the Court on February 1, 2021.

9. Attached here as Exhibit 8 is an email chain including an email from Plaintiff’s 

counsel Ryan Loveless responding to the February 8 Email.

10. Attached here as Exhibit 9 is Plaintiff’s Preliminary Constructions dated January 

20, 2021.

11. Attached here as Exhibit 10 are excerpts from the file history of U.S. Patent No. 

9,164,800 (“the ’800 patent”), specifically from the Amendment filed on April 13, 2015. These 

excerpts were retrieved from the United States Patent Office’s website 

(https://portal.uspto.gov/pair/PublicPair).

12. Attached here as Exhibit 11 is an Appendix titled “Verilog HDL Design,” which 

was retrieved from the following website: https://onlinelibrary.wiley.com/doi/pdf/

10.1002/9780470823798.app1 (last visited March 17, 2021).

13. Attached here as Exhibit 12 is an article titled “RTL (Register Transfer Level),” 

which was retrieved from the following website: https://semiengineering.com/knowledge_centers/

eda-design/definitions/register-transfer-level/ (last visited March 17, 2021). 

14. Attached here as Exhibit 13 is a document titled “IEEE Standard for Verilog® 

Hardware Description Language,” which was retrieved from the following website: 

https://www.eg.bucknell.edu/~csci320/2016-fall/wp-content/uploads/2015/08/verilog-std-1364-

2005.pdf (last visited March 17, 2021). 

Case 6:20-cv-00480-ADA Document 82-2 Filed 03/17/21 Page 3 of 4
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I declare under penalty of perjury that the foregoing is true and correct.

Dated: March 17, 2021

/s/ Jaysen S. Chung 

Jaysen S. Chung

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