Exhibit J

Case 6:20-cv-00473-ADA-DTG Document 239 Filed 11/16/22 Page 1 of 6
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Created: August 30, 2021 14:14:39 -6:00

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E-Sign: Yes

Hogan Declaration.pdf

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E-Signature Summary

E-Signature 1: Matt Hogan (MH)

Aug 30, 2021 14:19:34 -6:00 [426083609A7E] [99.120.169.64]

matt@brazoslicensing.com

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D O C V E R I F Y

Case 6:20-cv-00473-ADA-DTG Document 239 Filed 11/16/22 Page 2 of 6 Case 6:20-cv-01083-ADA Document 38 Filed 08/31/21 Page 1 of 5
IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

WSOU INVESTMENTS, LLC D/B/A

BRAZOS LICENSING AND 

DEVELOPMENT,

Plaintiff,

v.

ARISTA NETWORKS, INC.,

Defendant.

CIVIL ACTION NO. 6:20-cv-01083-ADA

JURY TRIAL DEMANDED

DECLARATION OF MATT HOGAN IN SUPPORT OF WSOU INVESTMENTS, LLC

D/B/A BRAZOS LICENSING AND DEVELOPMENT’S OPPOSITION TO ARISTA 

NETWORKS, INC.’S MOTION TO TRANSFER VENUE UNDER 28 U.S.C. § 1404(a)

I, Matt Hogan, being duly sworn, hereby state as follows:

1. I am the Managing Director of Business Development for WSOU Investments, 

LLC d/b/a Brazos Licensing and Development (“Brazos”) and have relevant knowledge of 

Brazos’s business operations. I am over the age of 21 and competent to make this declaration. I 

submit this declaration based on my personal knowledge and in support of Brazos’s Opposition to

Arista’s Opposed Motion to Transfer Venue.

2. Brazos is a Waco-based company that leverages its proprietary technology and 

management experience to help inventors and patent owners maximize the full potential of their 

patents. Brazos has a principal place of business at 605 Austin Ave., Suite 6, Waco, Texas 76701. 

Brazos maintains a website at https://www.brazoslicensing.com. Not only does Brazos operate out 

of downtown Waco (Brazos’s principal place of business), less than two blocks from the Waco 

Division Courthouse, Brazos has established deep roots within the Waco community.

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3. Brazos 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. Brazos considered me a good 

fit because of my family ties to the Waco community.

4. Before working with Brazos, 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 Brazos 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.

5. My first responsibility with Brazos was to supervise the build out of Brazos’s 3026 

square foot Waco office. In establishing its Waco headquarters, Brazos has purchased services 

from several local Waco companies. This includes, for example, an approximately $80,000

renovation project by a Waco construction company. Brazos 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. Brazos has also engaged in hiring students from 

Baylor Law School to support its business plan. In addition, Brazos is set to offer a PDP 

(Professional Development Program) session to students in the Hankamer School of Business at 

Baylor in the fall of 2021. Also, Brazos has proposed working with Baylor Law School’s 

Intellectual Property Law & Entrepreneurship Clinic to offer a webinar for Baylor law students. 

Brazos has proposed and is pursuing this as an ongoing quarterly series.

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

of local staff. Brazos has hired a full-time in-house attorney, Sheyanna Pietras, who lives in Troy 

and works in Waco and graduated from Baylor Law School. Sheyanna was hired on November 9,

2020. The hiring of new staff has been delayed by COVID-19 but may resume soon. Previously, 

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Brazos had posted openings on local job search boards such as Waco LPA, Startup Waco, and 

Waco TXjobs.

7. Before COVID-19 pandemic delayed its efforts, Brazos had proposed and began 

working on a collaboration with Startup Waco—a co-working space in downtown Waco that 

provides workspace for designers, developers, entrepreneurs, and business owners in the 

community.1 Brazos continues to pursue collaborations and business in Waco.

8. Since Brazos 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 

Brazos’s portfolio. I have also held several meetings in Waco with businesses and inventors to 

develop a plan to monetize their intellectual property and protect their interests. 

9. Brazos utilizes Heart of Texas Network Consultants—a local Waco business—to 

maintain its servers, which store its employee email accounts and electronic documents (including 

ownership and chain of title documents, all documents and correspondence regarding the patentsin-suit, and documents related to Brazos’s formation and business operations). All of Brazos’s 

physical documents are stored in Brazos’s Waco office, including, but not limited to patent-related 

documents and relevant correspondence and records from the USPTO. These documents have been 

located in Waco since at least October 2020. 

10. Brazos is headquartered in Waco. Brazos’s documents are there. Its business is 

there. Employees with relevant knowledge are there. Brazos has no offices, employees, or 

documents in NDCA. Visiting Brazos employees have full access to Brazos’s Waco facility, its 

high-speed internet connection, network printers and scanners, and documents. Brazos’s 

employees are willing to appear for trial in Waco, including Brazos’s President, Stuart Shanus, 

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

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and its CEO, Craig Etchegoyen, who are most knowledgeable about Brazos’s licensing practices, 

and doing so would not be inconvenient for them. This makes Waco more convenient for Brazos’s 

witnesses than NDCA.

11. A defendant in another Brazos case pending in the Western District has asked for 

my deposition during merits discovery. I expect to be deposed in that case along with Mr. Shanus 

and Mr. Etchegoyen near the end of September. 

I declare under penalty of perjury that the foregoing is true and correct to the best of my 

knowledge.

Executed on August 30, 2021.

Matt Hogan

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426083609A7E

Signed on 2021/08/30 14:19:34 -6:00

0DWW+RJDQ

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