EXHIBIT 4 

 

Case 6:20-cv-00505-ADA Document 53-2 Filed 04/02/21 Page 1 of 19
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IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

NEONODE SMARTPHONE LLC,

Plaintiff, 

v. 

APPLE INC., 

Defendant. 

Civil Action No. 6:20-cv-00505-ADA 

NEONODE SMARTPHONE LLC'S SECOND SUPPLEMENTAL AND AMENDED 

RESPONSES AND OBJECTIONS TO APPLE INC.'S VENUE INTERROGATORIES 

Pursuant to Federal Rules of Civil Procedure 26 and 33, Neonode Smartphone LLC 

("Neonode") hereby submits the following supplemental and amended responses and objections 

to Defendant Apple Inc.'s ("Apple") Venue Interrogatories dated December 14, 2020 

("Interrogatories"). 

GENERAL OBJECTIONS 

1. Neonode objects to Apple's "Definitions" and "Instructions" to the extent that they 

purport to impose burdens on Neonode that are broader than, additional to, inconsistent with, or 

not otherwise authorized by the Federal Rules of Civil Procedure, the applicable Local Rules 

("Local Rules"), or other rules, procedures, or orders of the Court. In responding to the 

Interrogatories, Neonode will comply with the Federal Rules of Civil Procedure, the Local Rules, 

and other rules, procedures, or orders of the Court.

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2. Neonode objects to the definition of "Plaintiff," "Neonode," "You," and "Your" as 

overbroad and vague. In responding to the Interrogatories, Neonode understands "Plaintiff," 

"Neonode," "You," and "Your" to refer to Neonode Smartphone LLC. 

3. Neonode objects to the definition of "Asserted Patents" because it is overbroad and 

factually incorrect in that extends to patents that are not asserted in this case. In responding to the 

Interrogatories, Neonode understands "Asserted Patents" to refer to the patents in suit, U.S. Patent 

No. 8,095,879 and U.S. Patent No. 8,812,993. 

4. Neonode objects to the definition of "Related Patents" because it is circular. 

5. Neonode objects to the Interrogatories to the extent that they seek disclosure of 

privileged information, including but not limited to information protected by the attorney-client 

privilege, the attorney work product doctrine, the joint defense privilege and common interest 

privilege. In responding to these Interrogatories, Neonode will not disclose privileged information, 

and the fact that Neonode does not specifically object to a request on the grounds that it seeks such 

privileged or protected information shall not be deemed a waiver of the protection afforded by any 

applicable privilege or protection. 

6. Investigation and discovery are ongoing in this case. The objections and responses 

set forth below are based upon information currently available to Neonode, and are made without 

prejudice to Neonode's right to use or rely on any subsequently discovered information. Neonode 

specifically reserves the right to supplement, amend, modify, and/or correct these responses during 

the venue discovery period. 

SPECIFIC RESPONSES AND OBJECTIONS 

VENUE INTERROGATORY NO. 1: 

Identify each person who has relevant knowledge to this case, including persons who may 

be deposed but are not under the Court's subpoena power for trial attendance, and describe the 

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subject matter of his or her relevant knowledge or expected testimony. As set forth in the 

Instructions, include an identification of each such person's name, title, team and/or organization 

name, the location where each such person resides and works, and contact information (i.e., phone 

number, address, and e-mail). 

RESPONSE TO VENUE INTERROGATORY 1: 

Neonode incorporates its General Objections and further objects to this Interrogatory, in 

particular to the phrase "relevant knowledge to this case," as vague and potentially overbroad 

depending upon the determination of relevance. Subject to and without waiving the foregoing 

objections, Neonode responds as follows: 

 Dooyong Lee. Manager of Neonode Smartphone LLC and Chief Executive Officer of 

Aequitas Technologies LLC. Mr. Lee's place of residence and work is Seoul, Republic of 

Korea. Mr. Lee's relevant knowledge may include plaintiff's ownership of the Asserted 

Patents and related rights by assignment of the Asserted Patents and related rights from 

Neonode Inc. to Aequitas Technologies LLC and then from Aequitas Technologies LLC 

to Neonode Smartphone LLC. Mr. Lee may be contacted through counsel for Neonode 

Smartphone LLC. 

 Anuj Arora. Director of Engineering, Aequitas Technologies LLC. Mr. Arora's place of 

residence and work is Torrance, California 90505. Mr. Arora's relevant knowledge may 

include pre-filing investigation and analyses of the alleged infringement of the Asserted 

Patents. Mr. Arora may be contacted through counsel for Neonode Smartphone LLC. 

 Magnus Goertz. Mr. Goertz was a founder of Neonode AB. Mr. Goertz's place of residence 

is believed to be . Mr. Goertz's relevant 

knowledge may include conception and reduction to practice of the invention claimed in 

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the Asserted Patents, commercialization of the inventions claimed in the Asserted Patents, 

secondary considerations of nonobviousness, communications with Samsung, and the 

Neonode Sweden AB – Samsung License Agreement. Mr. Goertz's email address is 

believed to be 

 Björn Thomas Eriksson. Mr. Eriksson was a co-founder of Neonode AB. Mr. Eriksson's 

place of residence is believed to be . Mr. 

Eriksson's relevant knowledge may include conception and reduction to practice of the 

invention claimed in the Asserted Patents, commercialization of the inventions claimed in 

the Asserted Patents, secondary considerations of nonobviousness, communications with 

Apple and Samsung, and the Neonode Sweden AB – Samsung License Agreement. Mr. 

Eriksson's email address is believed to be 

 Joseph Shain. Intellectual Property Manager, Neonode Technologies AB. Mr. Shain's place 

of residence is Stockholm, Sweden. Mr. Shain's place of work is Stockholm, Sweden. 

Mr. Shain's relevant knowledge may include commercialization of the inventions claimed 

in the Asserted Patents, secondary considerations of nonobviousness, prosecution of the 

applications that issued as the Asserted Patents, efforts to monetize the Asserted Patents, 

and communications with Apple and Samsung regarding the Asserted Patents. Mr. Shain 

may be contacted through counsel for Neonode Smartphone LLC. 

 Ulf Mårtensson. Executive Vice President Operations, Neonode, Inc. and Executive Vice 

President Operations, Neonode Technologies AB. Mr. Mårtensson's place of residence is 

Sweden. Mr. Mårtensson's place of work is Stockholm, Sweden. Mr. Mårtensson's relevant 

knowledge may include knowledge of Neonode Inc. technology license agreements and 

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knowledge of commercialization of the technology of the Asserted Patents, including 

production of devices embodying that technology and sales and marketing of such devices. 

 Marc Berger. Managing Director of Soquel Group Inc. Mr. Berger's place of residence and 

work is . Mr. Berger's relevant 

knowledge may include prosecution of the applications that issued as the Asserted Patents, 

and communications with Apple and Samsung regarding the Asserted Patents. Mr. Berger 

may be contacted through counsel for Neonode Smartphone LLC. 

SUPPLEMENTAL RESPONSE TO VENUE INTERROGATORY 1: 

Additional former Neonode AB employees and consultants who may have knowledge 

relevant to this case include: 

 Nina Johannesson. Ms. Johannesson was CFO of Neonode AB during the approximate 

period 2005-2010. Ms. Johannesson's place of residence and work is believed to be in or 

about Stockholm, Sweden. Ms. Johannesson's relevant knowledge may include business 

and financial aspects of Neonode AB's business as it relates to the N1 and N2 model 

phones, including such issues as sales and profits. 

 Tommy Hallberg. Mr Hallberg was COO and acting CEO of Neonode AB during the 

approximate period 2005-2008. Mr. Hallberg's place of residence and work is believed to 

be in or about Stockholm, Sweden. Mr. Hallberg's relevant knowledge may include 

business and financial aspects of Neonode AB's business as it relates to the N1 and N2 

model phones, including such issues as sales and profits. 

 Jonas Löfgren. Mr. Löfgren was involved with sales and marketing at Neonode AB during 

the approximate period 2002-2008. Mr. Löfgren's place of residence and work is believed 

to be in or about Stockholm, Sweden. Mr. Hallberg's relevant knowledge may include sales 

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and marketing of the N1 and N2 model phones, including product demonstrations. 

 Per Sundqvist. Mr. Sundqvist was an Account Manager at Noenode AB during the 

approximate period 2004-2008. Mr. Sundqvist's place of residence and work is believed to 

be in or about Nyköping, Sweden. Mr. Sundqvist's relevant knowledge may include sales 

and marketing of the N1 and N2 model phones, including product demonstrations. 

 Jonas Litborn. Mr. Litborn was Director of Customer Service at Neonode AB during the 

approximate period 2004-2009 and an advisory board member of Neonode AB during the 

approximate period 2009-2010. Mr. Litborn's place of residence and work is believed to be 

in or about Stockholm, Sweden. Mr. Litborn's relevant knowledge may include aftermarket 

service and support for the N1 and N2 model phones, as well as ownership of Neonode 

AB. 

 Mattias Häggström. Mr. Häggström was a Software Developer at Neonode AB during the 

approximate period 2003-2008. Mr. Häggström's place of residence and work is believed 

to be in or about Stockholm, Sweden. Mr. Häggström's relevant knowledge may include 

development of software for the N1 and N2 model phones, including software for 

implementation of touch user interface and other functionality. 

 Robert Pettersson. Mr. Pettersson was a Software Developer at Neonode AB starting in or 

about 2003. Mr. Pettersson is currently employed by Neonode Technologies AB. Mr. 

Pettersson's place of residence and work is Stockholm, Sweden. Mr. Pettersson's relevant 

knowledge may include development of software for the N1 and N2 model phones, 

including software for implementation of touch user interface and other functionality. 

Defendants may contact Mr. Pettersson through counsel for Neonode Inc. 

 Anders Hagberg. Mr. Hagberg was Lead Software Design Engineer at Neonode AB during 

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the approximate period 2003-2008. Mr. Hagberg's place of residence and work is believed 

to be in or about Stockholm, Sweden. Mr. Hagberg's relevant knowledge may include 

development of software for the N1 and N2 model phones, including software for 

implementation of touch user interface and other functionality. 

 Sam Peters. Mr. Peters is a co-founder and CEO of No Picnic AB, an industrial design 

consultant engaged by Neonode AB during the approximate period 2001-2002. Mr. Peters' 

place of residence and work is believed to be in or about Stockholm, Sweden. Mr. Peters' 

relevant knowledge may include design of the N1 model phone, including user interface 

and other design aspects. 

 Urban Ahlgren. Mr. Ahlgren is a co-founder No Picnic AB, an industrial design consultant 

first engaged by Neonode AB during the approximate period 2001-2002. Mr. Ahlgren's 

place of residence and work is believed to be in or about Stockholm, Sweden. Mr. Ahlgren's 

relevant knowledge may include design of the N1 model phone, including user interface 

and other design aspects. 

 Per Leine. Mr. Leine was a software and hardware engineer engaged as a consultant by 

Neonode AB during the approximate period 2002-2008. Mr. Leine's place of residence and 

work is believed to be in or about Stockholm, Sweden. Mr. Leine's relevant knowledge 

may include development of the N1 and N2 model phones, including aspects of the phones' 

displays and electronics.

VENUE INTERROGATORY NO. 2: 

Identify the custodians and non-custodial data sources that possess documents and/or 

evidence (whether physical or electronic) that are relevant to this case, stating the issues to which 

the documents and/or evidence pertains, where the custodians or data sources are located, whether 

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the documents and/or evidence are accessible from anywhere in the United States outside the 

Western District of Texas and if so, from where they are accessible. As set forth in the Instructions, 

include an identification of where each such custodian's name, title, team and/or organization 

name, the location where each such person resides and works, and contact information (i.e., phone 

number, address, and e-mail) and/or where each non-custodial data source resides. 

FIRST AMENDED RESPONSE TO VENUE INTERROGATORY NO. 2: 

Neonode incorporates its General Objections and further objects to this Interrogatory, in 

particular to the phrase "relevant to this case," as vague and potentially overbroad depending upon 

the determination of relevance. Subject to and without waiving the foregoing objections, Neonode 

responds as follows: 

 Dooyong Lee. Mr. Lee possesses documents and/or evidence in electronic format that are 

relevant to the ownership and chain of title of the Asserted Patents, infringement of the 

Asserted Patents, and damages for infringement of the Asserted Patents. Mr. Lee's 

documents in paper form are located at Mr. Lee's place of work in South Korea. Mr. Lee's 

documents in electronic format are stored in one or more servers/databases and are 

generally accessible from anywhere in the United States, including outside the Western 

District of Texas, where there is a reliable internet connection capable of supporting a 

virtual private network. See response to Interrogatory No. 1 for additional responsive 

information. 

 Anuj Arora. Mr. Arora possesses documents and/or evidence in electronic format that are 

relevant to pre-filing investigation and analyses of the alleged infringement of the Asserted 

Patents, prosecution of the applications that issued as the Asserted Patents, ownership and 

chain of title of the Asserted Patents, infringement of the Asserted Patents, and damages 

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for infringement of the Asserted Patents. Mr. Arora's documents are located on one or more 

servers/databases and are generally accessible from anywhere in the United States, 

including outside the Western District of Texas, where there is a reliable internet 

connection capable of supporting a virtual private network. See response to Interrogatory 

No. 1 for additional responsive information. 

 Magnus Goertz. Mr. Goertz may possess documents and/or evidence in electronic format, 

and physical evidence, relevant to at least the issues of conception and reduction to practice 

of the invention claimed in the Asserted Patents, commercialization of the inventions 

claimed in the Asserted Patents, secondary considerations of nonobviousness, 

communications with Samsung, and the Neonode Sweden AB – Samsung License 

Agreement. It is believed that documents and other evidence in Mr. Goertz's possession 

located and accessible in Sweden. Plaintiff is unaware whether documents and other 

evidence in Mr. Goertz's possession is accessible from outside of Sweden. See response to 

Interrogatory No. 1 for additional responsive information. 

 Björn Thomas Eriksson. Mr. Eriksson may possess documents and/or evidence in 

electronic format, and physical evidence, relevant to at least the issues of conception and 

reduction to practice of the invention claimed in the Asserted Patents, commercialization 

of the inventions claimed in the Asserted Patents, secondary considerations of 

nonobviousness, communications with Samsung, and the Neonode Sweden AB – Samsung 

License Agreement. It is believed that documents and other evidence in Mr. Eriksson's 

possession located and accessible in Sweden. Plaintiff is unaware whether documents and 

other evidence in Mr. Eriksson's possession is accessible from outside of Sweden. See 

response to Interrogatory No. 1 for additional responsive information. 

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 Joseph Shain. Mr. Shain has access to documents in electronic format relevant to at least 

the issues of Neonode Inc. technology license agreements and prosecution of the Asserted 

Patents. Mr. Shain has access to documents in electronic format, and physical evidence, 

relevant to commercialization of the patented technology. The documents are located on 

one or more servers/databases and are generally accessible from anywhere in the United 

States, including outside the Western District of Texas, where there is a reliable internet 

connection capable of supporting a virtual private network. Physical evidence, including 

commercial embodiments of devices incorporating the technology of the Asserted Patents, 

is located in Sweden and Israel. Defendants may contact Mr. Shain through counsel for 

Neonode Smartphone LLC. See response to Interrogatory No. 1 for additional responsive 

information. 

 Ulf Mårtensson. Mr. Mårtensson has access to documents in electronic format relevant to 

at least the issues of Neonode Inc. technology license agreements and commercialization 

of the patented technology. Mr. Mårtensson has access to documents in electronic format, 

and physical evidence, relevant to commercialization of the patented technology. The 

documents are located on one or more servers/databases and are generally accessible from 

anywhere in the United States, including outside the Western District of Texas, where there 

is a reliable internet connection capable of supporting a virtual private network. Physical 

evidence, including commercial embodiments of devices incorporating the technology of 

the Asserted Patents, is located in Sweden. See response to Interrogatory No. 1 for 

additional responsive information. Defendants may contact Mr. Mårtensson through 

counsel for Neonode Inc. 

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 Marc Berger. Mr. Berger possesses documents in electronic format that are relevant to 

prosecution of the applications that issued as the Asserted Patents and to efforts to monetize 

the Asserted Patents. Mr. Berger's documents are stored on a computer at his place of work 

in Israel and are not are generally accessible from places within the United States. See 

response to Interrogatory No. 1 for additional responsive information. 

VENUE INTERROGATORY NO. 3: 

Describe in complete detail all communications and the relationship between Neonode 

Smartphone LLC, Magnus Goertz, Neonode Inc., Aequitas Technologies, LLC, and/or any other 

entities associated with Neonode Smartphone, LLC, Neonode Inc., and/or Aequitas Technologies, 

LLC including an identification of all relevant individuals employed by these entities, the subject 

matter of his or her relevant knowledge, each such person's name, title, team and/or organization 

name, the location where each such person resides and works, and contact information (i.e., phone 

number, address, and e-mail). 

RESPONSE TO VENUE INTERROGATORY NO. 3: 

Neonode incorporates its General Objections and further objects to this Interrogatory, in 

particular the request to "[d]escribe in complete detail all communications," because it is 

unreasonable and unduly burdensome, is not directed to evidence that is relevant to venue-related 

issues, and includes privileged communications. Subject to and without waiving the foregoing 

objections, Neonode responds as follows: 

Neonode Smartphone LLC is a Wyoming limited liability company having a principal 

place of business in Sheridan, Wyoming. Neonode Smartphone, LLC has no employees. Dooyong 

Lee is the Manager of Neonode Smartphone LLC, which is 100% owned by Aequitas 

Technologies LLC. Aequitas Technologies LLC's employees include Dooyong Lee (Chief 

Executive Officer) and Anuj Arora (Director of Engineering). 

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Magnus Goertz and others were investors in a company that was renamed Neonode AB in 

2005. Subsequently, Neonode AB became a subsidiary of Neonode, Inc. In 2008, Neonode AB 

assigned its intellectual property to Neonode, Inc. and thereafter was liquidated. Also in 2008, 

Neonode, Inc. acquired a subsidiary that was re-named Neonode Technologies AB. Neither 

Neonode Inc., Neonode Technologies AB, nor Magnus Goertz has an ownership interest in 

Aequitas Technologies LLC or Neonode Smartphone LLC. 

Aequitas Technologies LLC has had communications with Neonode Inc. relevant to the 

subject matter of this action, including but not limited to communications concerning the Asserted 

Patents, assignment of the Asserted Patents, infringement of the Asserted Patents, and damages 

for infringement of the Asserted Patents. 

See response to Interrogatory No. 1 for additional responsive information. 

SUPPLEMENTAL RESPONSE TO VENUE INTERROGATORY NO. 3: 

Documents from which additional responsive information may be derived or ascertained 

include NEONODE0001389-90; NEONODE0001391-93; NEONODE0001394-96; 

NEONODE0000707-708; NEONODE0000709-711; NEONODE0000712-727; 

NEONODEINC0000270-285; NEONODEINC0000286-301; NEONODEINC0000302; 

NEONODEINC0000303-04; NEONODEINC0000309; and NEONODEINC0000310-312; 

NEONODEINC0000335-336. 

VENUE INTERROGATORY NO. 4: 

Identify all Neonode Smartphone, LLC employees by name, title, team and/or organization 

name, location, and relevant knowledge, and provide contact information (i.e., phone number, 

address, and e-mail) for each such individual. 

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RESPONSE TO VENUE INTERROGATORY NO. 4: 

Subject to and without waiving its General Objections, Neonode states that it has no 

employees. 

VENUE INTERROGATORY NO. 5: 

Identify all Neonode Smartphone, LLC investors or those with a financial interest in the 

outcome of this lawsuit by name, title, team and/or organization name, location, and relevant 

knowledge, and provide contact information (i.e., phone number, address, and e-mail) for each 

such individual. 

RESPONSE TO VENUE INTERROGATORY NO. 5: 

Neonode incorporates its General Objections and further objects to this Interrogatory, in 

particular the request to "[i]dentify all Neonode Smartphone, LLC investors or those with a 

financial interest in the outcome of this lawsuit," because it is not directed to evidence that is 

relevant to venue-related issues. On the basis of this objection, Neonode will not answer this 

interrogatory. 

VENUE INTERROGATORY NO. 6: 

Identify any persons and/or entities who have relevant knowledge about any product You 

contend embodies the Asserted Patents, including an identification of where each such person 

resides and works. 

RESPONSE TO VENUE INTERROGATORY NO. 6: 

Subject to and without waiving its General Objections, Neonode responds as follows: 

Persons and entities who have relevant knowledge about Neonode-branded products that 

embody the Asserted Patents include Neonode, Inc., Neonode Technologies AB, Joseph Shain, 

Ulf Mårtensson, Magnus Goertz, and Björn Thomas Eriksson. See original and supplemental 

responses to Interrogatory No. 1 for additional responsive information. 

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Persons and entities who have relevant knowledge about Apple-branded products that 

embody the Asserted Patents include Apple, Inc. and persons knowledgeable about the 

functionality of the accused Apple products as described in Neonode's Complaint in 6:20-cv-00505 

(W.D. Tex.) and infringement contentions directed to Apple. The identities and places of residence 

and employment of such persons are currently unknown. 

Persons and entities who have relevant knowledge about Samsung-branded products that 

embody the Asserted Patents include Samsung Electronics Co., Ltd. and Samsung Electronics 

America, Inc. (collectively, "Samsung") and persons knowledgeable about the functionality of the 

accused Samsung products as described in Neonode's Complaint in 6:20-cv-00507 (W.D. Tex.) 

and in Neonode's infringement contentions directed to Samsung. The identities and places of 

residence and employment of such persons are currently unknown. 

VENUE INTERROGATORY NO. 7: 

Explain the complete factual and legal basis for Your contention that individuals or 

facilities in or near Western District of Texas have evidence relevant to the Accused Products or 

any claim or defense in this litigation. 

RESPONSE TO VENUE INTERROGATORY NO. 7: 

Subject to and without waiving its General Objections, Neonode responds as follows: 

Apple has retail locations in the Western District of Texas, including in at least the cities 

of El Paso, San Antonio, and Austin. See https://www.apple.com/retail/storelist/. At those retail 

locations Apple conducts infringing activities, including selling and offering to sell infringing 

devices identified in Neonode's complaint in this case and in Neonode's infringement contentions 

directed to Apple. In addition, Neonode expects to discover that Apple has sent, transmitted, or 

delivered each of the following to numerous users’ Apple devices in the Western District of Texas: 

(a) QuickPath; (b) a Third Party Swipe-Typing Keyboard App; (c) iOS 8; (d) iPadOS; (e) later 

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version(s) of iOS; and (f) later versions of iPadOS, thereby directly or indirectly infringing one or 

both of the Asserted Patents. 

VENUE INTERROGATORY NO. 8: 

To the extent any individual listed in response to Interrogatory No. 1 has traveled to the 

Northern District of California in the past three years in relation to the Asserted Patents or any 

product that allegedly practices the Asserted Patents, identify such travel, including the number of 

trips, approximate length of trips, and any reason the individual(s) would not be able to travel to 

the Northern District of California in the next three years. 

RESPONSE TO VENUE INTERROGATORY NO. 8: 

Subject to and without waiving its General Objections, Neonode responds as follows: 

Neither Mr. Lee, Mr. Arora, Mr. Shain, Mr. Mårtensson, nor Mr. Berger has traveled to the 

Northern District of California in the past three years in relation to the Asserted Patents or any 

product that allegedly practices the Asserted Patents. Neonode is not aware whether, and has no 

reason to believe that, Mr. Goertz, Mr. Eriksson, Ms. Johannesson, Mr. Hallberg, Mr. Löfgren, 

Mr. Sundqvist, Mr. Litborn, Mr. Häggström, Mr. Pettersson, Mr. Hagberg, Mr. Peters, Mr. 

Ahlgren, or Mr. Leine has traveled to the Northern District of California in the past three years in 

relation to the Asserted Patents or any product that allegedly practices the Asserted Patents. 

VENUE INTERROGATORY NO. 9: 

Identify all unique documents you contend are only accessible from the Western District 

of Texas and any unique physical documents you contend are only located in the Western District 

of Texas, including a description of their contents and relevance to this lawsuit. 

RESPONSE TO VENUE INTERROGATORY NO. 9: 

Subject to and without waiving its General Objections, Neonode responds as follows: 

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Neonode is not currently aware of any unique documents that are only accessible from the 

Western District of Texas or of any unique physical documents that are only located in the Western 

District of Texas. 

VENUE INTERROGATORY NO. 10: 

Identify all customers of Neonode Smartphone, LLC and/or Neonode Inc. relating to 

technology or products embodying the Asserted Patents in the Northern District of California, 

including an identification of where each such client resides and/or is located. 

AMENDED RESPONSE TO VENUE INTERROGATORY NO. 10: 

Subject to and without waiving its General Objections, Neonode responds as follows: 

Documents from which responsive information may be derived or ascertained include 

NEONODE0000728. 

DATED: April 2, 2021 As to objections, 

By: /s/ Greer Shaw 

Philip J. Graves (CA State Bar No. 153441) 

HAGENS BERMAN SOBOL SHAPIRO LLP 

301 North Lake Avenue, Suite 920 

Pasadena, CA 91101 

Telephone: (213) 330-7147 

Facsimile: (213) 330-7152 

Email: philipg@hbsslaw.com

Greer N. Shaw (CA State Bar No. 197960) 

HAGENS BERMAN SOBOL SHAPIRO LLP 

301 North Lake Avenue, Suite 920 

Pasadena, CA 91101 

Telephone: (213) 330-7150 

Facsimile: (213) 330-7152 

Email: greers@hbsslaw.com

Counsel for Plaintiff Neonode Smartphone LLC 

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CERTIFICATE OF SERVICE 

STATE OF CALIFORNIA, COUNTY OF LOS ANGELES 

At the time of service, I was over 18 years of age and not a party to this action. I am 

employed in the City and County of Los Angeles, State of California. My business address is 

Hagens Berman Sobol & Shapiro, 301 North Lake Avenue, Suite 920, Pasadena, CA 91101. 

On April 2, 2021, I served true copies of the following document described as the 

following: 

NEONODE SMARTPHONE LLC'S SECOND SUPPLEMENTAL AND AMENDED 

RESPONSES AND OBJECTIONS TO APPLE INC.'S VENUE INTERROGATORIES 

on the interested parties in this action listed below via e-mail: 

 /s/ William Stevens 

 William Stevens 

Betty H. Chen 

Fish & Richardson PC 

111 Congress Avenue, Suite 810 

Austin, TX 78701 

(512) 472-5070 

Fax: 512/320-8935 

Email: Bchen@fr.com 

Benjamin C. Elacqua 

Kathryn A. Quisenberry 

Fish and Richardson PC 

1221 McKinney Street Suite 2800 

Houston, TX 77010 

713-654-5300 

Fax: 713-652-0109 

Email: Elacqua@fr.com 

Email: Quisenberry@fr.com 

Attorneys for Defendant Apple Inc.

Jared A. Smith 

Fish & Richardson P.C. 

12860 El Camino Real, Suite 400 

San Diego, CA 92130 

(858) 678-5070 

Fax: (878) 678-5099 

Email: Jasmith@fr.com 

Aamir A. Kazi 

Fish & Richardson P.C. 

1180 Peachtree Street NE, 21st Floor 

Atlanta, GA 90309 

(404) 892-5005 

Fax: (404) 892-5002 

Email: kazi@fr.com 

Case 6:20-cv-00505-ADA Document 53-2 Filed 04/02/21 Page 18 of 19
VERIFICATION 

I, Dooyong Lee, the Manager of Neonode Smartphone LLC, have read Neonode 

Smartphone LLC's Second Supplemental and Amended Responses to Apple's Venue 

Interrogatories, and certify under penalty of perjury that the foregoing responses are true and 

correct to the best of my knowledge, information, and belief.

Executed on April 2, 2021.

____________________________

Dooyong Lee

DocuSign Envelope ID: 3540450D-13DC-4E05-A301-F8F0D8D80752 Case 6:20-cv-00505-ADA Document 53-2 Filed 04/02/21 Page 19 of 19