EXHIBIT 17

Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 1 of 49
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 2 of 49 Case 6:20-cv-00454-ADA Document 32-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 3 of 49 Case 6:20-cv-00454-ADA Document 32-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 4 of 49 Case 6:20-cv-00455-ADA Document 28-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 5 of 49 Case 6:20-cv-00455-ADA Document 28-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 6 of 49 Case 6:20-cv-00456-ADA Document 29-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 7 of 49 Case 6:20-cv-00456-ADA Document 29-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 8 of 49 Case 6:20-cv-00457-ADA Document 28-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 9 of 49 Case 6:20-cv-00457-ADA Document 28-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 10 of 49 Case 6:20-cv-00458-ADA Document 30-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 11 of 49 Case 6:20-cv-00458-ADA Document 30-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 12 of 49 Case 6:20-cv-00459-ADA Document 28-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 13 of 49 Case 6:20-cv-00459-ADA Document 28-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 14 of 49 Case 6:20-cv-00460-ADA Document 30-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 15 of 49 Case 6:20-cv-00460-ADA Document 30-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 16 of 49 Case 6:20-cv-00461-ADA Document 30-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 17 of 49 Case 6:20-cv-00461-ADA Document 30-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 18 of 49 Case 6:20-cv-00462-ADA Document 30-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 19 of 49 Case 6:20-cv-00462-ADA Document 30-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 20 of 49 Case 6:20-cv-00463-ADA Document 28-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 21 of 49 Case 6:20-cv-00463-ADA Document 28-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 22 of 49 Case 6:20-cv-00464-ADA Document 30-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 23 of 49 Case 6:20-cv-00464-ADA Document 30-1 Filed 10/16/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 24 of 49 Case 6:20-cv-00465-ADA Document 30-1 Filed 10/16/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 25 of 49 Case 6:20-cv-00465-ADA Document 30-1 Filed 10/16/20 Page 2 of 2
 

	

  

 

  	 
  
   	 	 	    		  	 


	
 	  	 		
 	 

  	 		  	 	  	 

 	 
 
	  
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 Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 27 of 49 Case 6:20-cv-00473-ADA Document 51-5 Filed 11/18/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 28 of 49 Case 6:20-cv-00487-ADA Document 36-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 29 of 49 Case 6:20-cv-00487-ADA Document 36-2 Filed 11/06/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 30 of 49 Case 6:20-cv-00488-ADA Document 34-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 31 of 49 Case 6:20-cv-00488-ADA Document 34-2 Filed 11/06/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 32 of 49 Case 6:20-cv-00489-ADA Document 35-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 33 of 49 Case 6:20-cv-00489-ADA Document 35-2 Filed 11/06/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 34 of 49 Case 6:20-cv-00490-ADA Document 32-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 35 of 49 Case 6:20-cv-00490-ADA Document 32-2 Filed 11/06/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 36 of 49 Case 6:20-cv-00491-ADA Document 34-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 37 of 49 Case 6:20-cv-00491-ADA Document 34-2 Filed 11/06/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 38 of 49 Case 6:20-cv-00492-ADA Document 34-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 39 of 49 Case 6:20-cv-00492-ADA Document 34-2 Filed 11/06/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 40 of 49 Case 6:20-cv-00493-ADA Document 33-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 41 of 49 Case 6:20-cv-00493-ADA Document 33-2 Filed 11/06/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 42 of 49 Case 6:20-cv-00494-ADA Document 34-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 43 of 49 Case 6:20-cv-00494-ADA Document 34-2 Filed 11/06/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 44 of 49 Case 6:20-cv-00495-ADA Document 34-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 45 of 49 Case 6:20-cv-00495-ADA Document 34-2 Filed 11/06/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 46 of 49 Case 6:20-cv-00496-ADA Document 34-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 47 of 49 Case 6:20-cv-00496-ADA Document 34-2 Filed 11/06/20 Page 2 of 2
Page 1

DECLARATION OF MATT HOGAN

1. My name is Matt Hogan. I am over the age of 21 and am competent to make this 

declaration. The facts stated herein are within my personal knowledge and are true and correct. I 

am the Managing Director of Business Development for WSOU Investments, LLC d/b/a Brazos 

Licensing and Development (“WSOU”). WSOU is a Waco-based company that leverages its 

proprietary technology and management experience to help investors and patent owners maximize 

the full potential of their patents. It has a principal place of business at 605 Austin Ave., Suite 6, 

Waco, Texas 76701. WSOU maintains a website at https://www.brazoslicensing.com. Not only 

does WSOU operate out of downtown Waco (WSOU’s principal place of business), less than two 

blocks from the Waco Division Courthouse, WSOU has established deep roots within the Waco 

community

2. Before working with WSOU, I spent 7 years in traditional finance. After Wall 

Street, I was founding CEO of a company that pioneered consumer data control. I began discussions 

with WSOU in November 2019 and became an employee in January 2020. My wife and her family 

are Baylor alumni and wanted to move to Waco. In February 2020, my wife and I moved from New 

York to Waco.

3. WSOU chose Waco as its headquarters because it was attracted to what it sees as a 

burgeoning tech business in Waco, with Baylor acting as the anchor. WSOU specifically chose not 

to set up in Austin because it considered the market saturated. WSOU considered me a good fit 

because of my family ties to the Waco community. 

4. My first responsibility with WSOU was to supervise the build out of WSOU’s 

Waco office. In establishing its Waco headquarters, WSOU has purchased services from several 

local Waco companies. This includes, for example, an approximately $80,000 renovation project 

by a Waco construction company. WSOU also established a banking relationship with a local bank, 

hired local vendors to help support its litigation efforts, and supported Baylor’s COVID-19 relief 

efforts. WSOU utilizes a local business to maintain its servers. 

5. After supervising the build out of WSOU’s office, I turned my efforts to the hiring 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 48 of 49 Case 6:20-cv-00497-ADA Document 34-2 Filed 11/06/20 Page 1 of 2
Page 2

of local staff. WSOU has already engaged in hiring students from Baylor University to support its 

business plan . WSOU is also working with the Baylor Law IP clinic to offer a quarterly webinar 

series for Baylor law students. WSOU also has job postings in Waco LPA, Startup Waco, and Waco 

TXjobs. The hiring of new staff has been delayed by COVID-19 but will resume soon. Before 

COVID-19 delayed its efforts, WSOU was working to start a local tech meetup in Waco. With 

Startup Waco1 recently re-opening on a limited basis, WSOU has already resumed its collaborative 

efforts in the community.

6. Since WSOU opened its office in Waco, I have been engaged with private equity 

firms, investment bankers, and hedge fund managers to find additional opportunities and increase 

WSOU’s portfolio. I have also held several meetings with business and inventors to develop a plan 

to monetize their intellectual property and protect their interests. In furtherance of the business plan 

WSOU developed in 2019 and began executing in Waco in January 2020, WSOU has had ongoing 

email correspondence with Waco Ventures, a group that manages outside-facing dealings for the 

Baylor Transfer Technology Office. Id. WSOU has job postings in Waco LPA, Startup Waco, and 

Waco TXjobs, and is in the search process to hire several Baylor students. Id.

7. The Waco office is WSOU’s only office. Its documents are there. Its business is 

there. Visiting WSOU employees have full access to WSOU’s Waco facility, its high-speed internet 

connection, network printers and scanners, and documents. This makes Waco more convenient for 

WSOU’s witnesses than Austin. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct and executed on October 16, 2020.

Matt Hogan

1 Startup Waco is in downtown Waco and is a place for designers, developers, entrepreneurs, and 

others interested in the Waco startup community to connect. 

See https://members.startupwaco.com/. 

DocuSign Envelope ID: 34137513-CA31-4C91-9D81-D7110666685B Case 6:20-cv-00480-ADA Document 58-2 Filed 11/25/20 Page 49 of 49 Case 6:20-cv-00497-ADA Document 34-2 Filed 11/06/20 Page 2 of 2