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 6:20-cv-00454-ADA

CIVIL ACTION 6:20-cv-00455-ADA

CIVIL ACTION 6:20-cv-00456-ADA

CIVIL ACTION 6:20-cv-00457-ADA

CIVIL ACTION 6:20-cv-00458-ADA

CIVIL ACTION 6:20-cv-00459-ADA

CIVIL ACTION 6:20-cv-00460-ADA

CIVIL ACTION 6:20-cv-00461-ADA

CIVIL ACTION 6:20-cv-00462-ADA

CIVIL ACTION 6:20-cv-00463-ADA

CIVIL ACTION 6:20-cv-00464-ADA

CIVIL ACTION 6:20-cv-00465-ADA

DECLARATION OF IRENE YANG IN SUPPORT OF MICROSOFT CORPORATION’S 

MOTION TO TRANSFER VENUE TO AUSTIN DIVISION

Case 6:20-cv-00454-ADA Document 31-3 Filed 10/02/20 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 Intra-District Transfer to the 

Austin Division of the Western District of Texas in the above-captioned litigation

and the eleven 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 1 is a true and correct copy of a document 

entitled “State of Delaware Certificate of Formation of Limited Liability 

Company” for WSOU. 

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

Real/Frame 43953/822, downloaded from the USPTO assignments database at 

http://legacy-assignments.uspto.gov/assignments/assignment-pat-43953-822.pdf.

4. Attached hereto as Exhibit 3 is a true and correct copy of documents 

from the Texas Secretary of State records for WSOU entitled “Assumed Name 

Certificate” and “Application for Registration of a Foreign Limited Liability 

Company.”

5. Attached hereto as Exhibit 4 is a true and correct copy of a document 

entitled “Comprehensive Business Report” on WSOU from Dun & Bradstreet.

6. Attached hereto as Exhibit 5 is a true and correct copy of a list of 

cases filed by WSOU in the Western District of Texas, downloaded from the 

DocketNavigator service at http://search.docketnavigator.com on October 1, 2020.

7. Attached hereto as Exhibit 6 is a true and correct copy of a page from 

Plaintiff’s website, last visited on October 1, 2020. 

Case 6:20-cv-00454-ADA Document 31-3 Filed 10/02/20 Page 2 of 4
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8. Attached hereto as Exhibit 7 is a true and correct copy of a LinkedIn 

page for Craig Etchegoyen.

9. Attached hereto as Exhibit 8 is a true and correct copy of web pages 

indicating the geographical location of Stuart Shanus, last visited on October 2, 

2020.

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

page for Aaron Garvey.

11. Attached hereto as Exhibit 10 is a true and correct copy of a LinkedIn 

page for Matthew Hogan. 

12. Attached hereto as Exhibit 11 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 October 1, 2020.

13. Attached hereto as Exhibit 12 is a true and correct copy of a list of 

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

October 1, 2020.

14. Attached hereto as Exhibit 13 is a true and correct copy of a Google 

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

visited on October 1, 2020.

15. Attached hereto as Exhibit 14 is a true and correct copy of a Google 

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

visited on October 1, 2020. 

16. Attached hereto as Exhibit 15 is a true and correct copy of a set of 

publicly available webpages that indicate the geographical locations of certain 

inventors of patents asserted by WSOU against Microsoft in the 12 lawsuits filed 

by WSOU. These webpages were last visited on October 2, 2020.

Case 6:20-cv-00454-ADA Document 31-3 Filed 10/02/20 Page 3 of 4
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17. Attached hereto as Exhibit 16 is a true and correct copy of printouts 

from Google Maps that show the driving distance between certain counties in the 

Eastern District of Texas and Waco. 

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

from Google Maps that show the driving distance between certain counties in the 

Eastern District of Texas and Austin. 

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

that the foregoing is true and correct.

Executed on October 2, 2020 in San Francisco, California.

Irene Yang

Case 6:20-cv-00454-ADA Document 31-3 Filed 10/02/20 Page 4 of 4