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., 

AND EMC CORPORATION,

Defendants.

Case No. 6:20-cv-00482-ADA

JURY TRIAL DEMANDED

DECLARATION OF BRIAN A. ROSENTHAL IN SUPPORT OF

DEFENDANTS’ OPPOSED MOTION FOR INTRA-DISTRICT TRANSFER OF VENUE 

TO THE AUSTIN DIVISION OF THE WESTERN DISTRICT OF TEXAS

Case 6:20-cv-00482-ADA Document 44-2 Filed 11/04/20 Page 1 of 4
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I, Brian A. Rosenthal, 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 New York and the District of Columbia. I am a partner with the law 

firm of Gibson, Dunn & Crutcher LLP and counsel of record for Defendants Dell Technologies 

Inc., Dell Inc., and EMC Corporation 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 hereto as Exhibit 1 is a true and correct copy of the entity details for 

WSOU Investments, LLC obtained by searching for “WSOU Investments” at 

https://icis.corp.delaware.gov/ecorp/entitysearch/NameSearch.aspx on November 3, 2020.

3. Attached hereto as Exhibit 2 is a true and correct copy of assignment Real/Frame 

052372/0675, retrieved from the United States Patent Office’s website (http://legacyassignments.uspto.gov/assignments/assignment-pat-52372-675.pdf) on November 3, 2020.

4. Attached hereto as Exhibit 3 is a true and correct copy of assignment Real/Frame 

044000/0053, retrieved from the United States Patent Office’s website (http://legacyassignments.uspto.gov/assignments/assignment-pat-44000-53.pdf) on November 3, 2020.

5. Attached hereto as Exhibit 4 is a true and correct copy of the LinkedIn Profile of 

Stuart A. Shanus, retrieved from LinkedIn’s website (https://www.linkedin.com/in/stuart-a-s60a7695/) on November 3, 2020.

6. Attached hereto as Exhibit 5 is a true and correct copy of the LinkedIn Profile of 

Craig Etchegoyen, retrieved from LinkedIn’s website (https://www.linkedin.com/in/craigetchegoyen-aa8a07199/) on November 3, 2020.

Case 6:20-cv-00482-ADA Document 44-2 Filed 11/04/20 Page 2 of 4
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7. Attached hereto as Exhibit 6 is a true and correct copy of the website 

http://www.wadeandcompany.com/#contact, retrieved on November 3, 2020.

8. Attached hereto as Exhibit 7 is a true and correct copy of an article titled “AQUA 

Licensing to Manage Sale of Second Large Portfolio of Former Nokia and Alcatel-Lucent 

Telecommunications Patents,” obtained from https://www.businesswire.com/news/home/

20180207005651/en/AQUA-Licensing-to-Manage-Sale-of-Second-Large-Portfolio-of-FormerNokia-and-Alcatel-Lucent-Telecommunications-Patents on November 3, 2020.

9. Attached hereto as Exhibit 8 is a true and correct copy of the website 

https://www.brazoslicensing.com/about, retrieved on November 3, 2020.

10. Attached hereto as Exhibit 9 is a true and correct copy of the website 

https://www.transition.com/contact-us/our-headquarters/, retrieved on November 3, 2020.

11. Attached hereto as Exhibit 10 is a true and correct copy of an excerpt from the file 

history of U.S. Patent No. 7,424,020, specifically from a October 3, 2002 Transmittal of New 

Application. This excerpt was retrieved from the United States Patent Office’s website 

(https://portal.uspto.gov/pair/PublicPair) on November 3, 2020.

12. Attached hereto as Exhibit 11 is a true and correct copy of flights from 

Prosselsheim, Germany to Austin, Texas and from Prosselsheim, Germany to Waco, Texas 

obtained from the website Google Flights (https://www.google.com/flights), on November 3, 

2020. 

13. Attached hereto as Exhibit 12 is a true and correct copy of the price graph of flights 

from Prosselsheim, Germany to Austin, Texas and from Prosselsheim, Germany to Waco, Texas 

obtained from the website Google Flights (https://www.google.com/flights), on November 3, 

2020. 

Case 6:20-cv-00482-ADA Document 44-2 Filed 11/04/20 Page 3 of 4
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14. Attached hereto as Exhibit 13 is a true and correct copy of the website 

https://assignment.uspto.gov/patent/index.html#/patent/search/resultAbstract?id=7424020&type

=patNum, retrieved on November 3, 2020.

15. Attached hereto as Exhibit 14 is a true and correct copy of the price graph of flights 

from Paris, France to Austin, Texas and from Paris, France to Waco, Texas obtained from the 

website Google Flights (https://www.google.com/flights), on November 3, 2020. 

16. Attached hereto as Exhibit 15 is a true and correct copy of flights from San 

Francisco, California to Austin, Texas and from San Francisco, California to Waco, Texas obtained 

from the website Google Flights (https://www.google.com/flights), on November 3, 2020.

17. Attached hereto as Exhibit 16 is a true and correct copy of a document titled “IBM 

8275 Fast Ethernet Workgroup Switch Models 318, 322 and 326,” obtained from 

ftp://ftp.boulder.ibm.com/networking/nswww/did/nhs4590f.pdf on November 3, 2020.

18. Attached hereto as Exhibit 17 is a true and correct copy of the website 

https://www.research.ibm.com/labs/austin/, retrieved on November 3, 2020.

19. Attached hereto as Exhibit 18 is a true and correct copy of flights from Los 

Angeles, California to Austin, Texas and from Los Angeles, California to Waco, Texas obtained 

from the website Google Flights (https://www.google.com/flights), on November 3, 2020.

20. Attached hereto as Exhibit 19 is a true and correct copy of flights from KailuaKona, Hawaii to Austin, Texas and from Kailua-Kona, Hawaii to Waco, Texas obtained from the 

website Google Flights (https://www.google.com/flights), on November 3, 2020.

I declare under penalty of perjury that the foregoing is true and correct.

Dated: November 4, 2020

/s/ Brian A. Rosenthal___ Brian A. Rosenthal

Case 6:20-cv-00482-ADA Document 44-2 Filed 11/04/20 Page 4 of 4