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IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

WSOU INVESTMENTS, LLC d/b/a

BRAZOS LICENSING AND

DEVELOPMENT,

Plaintiff,

v.

MICROSOFT CORPORATION, 

Defendant.

Civil Action No. 6:20-cv-00454-ADA

Civil Action No. 6:20-cv-00455-ADA

Civil Action No. 6:20-cv-00456-ADA

Civil Action No. 6:20-cv-00458-ADA

Civil Action No. 6:20-cv-00459-ADA

Civil Action No. 6:20-cv-00460-ADA

Civil Action No. 6:20-cv-00461-ADA

Civil Action No. 6:20-cv-00462-ADA

Civil Action No. 6:20-cv-00463-ADA

Civil Action No. 6:20-cv-00464-ADA

JURY TRIAL DEMANDED

DECLARATION OF IRENE YANG IN SUPPORT OF DEFENDANT MICROSOFT 

CORPORATION’S OPPOSITION TO CORRECTED RULE 26 MOTION FOR 

PROTECTIVE ORDER BY NON-PARTY WADE & COMPANY (USA), INC. 

AND BY WSOU INVESTMENTS LLC

I, Irene Yang, declare as follows:

1. I am an attorney at Sidley Austin LLP, and counsel for Defendant Microsoft 

Corp. (“Microsoft”) in this matter. I am a member of the bar of this Court and admitted to 

practice law before this Court. I have personal knowledge of the facts set forth herein, and, if 

called as a witness, I could and would testify competently hereto. I am submitting this 

declaration in support of Microsoft’s opposition to Non-Party Wade & Company (USA), Inc. 

(“Wade”) and Plaintiff WSOU Investments LLC (“WSOU”) Motion for Protective Order.

2. Attached hereto as Exhibit 1 is a true and correct copy of Microsoft’s Subpoenas

to Third-Party Wade & Company (USA) Inc. (“Wade”). As of the date of this declaration, Wade 

Case 6:20-cv-00458-ADA Document 72-1 Filed 09/03/21 Page 1 of 3
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has not served objections to the deposition subpoena. 

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

between counsel for Microsoft and counsel for Wade. 

4. Attached hereto as Exhibit 3 is a true and correct copy of the proofs of service of 

Microsoft’s Subpoenas to Wade, signed April 12, 2021.

5. Attached hereto as Exhibit 4 is a true and correct copy of Wade’s Statement of 

Information filed with the office of the Secretary of State of California on September 13, 2018.

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

Wade’s website (http://www.wadeandcompany.com/), as accessed August 23, 2021. 

7. Attached hereto as Exhibit 6A is a true and correct copy of an excerpt of the 

patent assignment record corresponding to Reel/Frame 044000/0136 through 044000/0290, 

downloaded from the USPTO’s Patent Assignment database 

(https://assignment.uspto.gov/patent/index.html#/patent/search). The assignment record was 

excerpted to omit the USPTO Patent Assignment Cover Sheet spanning from Reel/Frame 

044000/0053 through 044000/00135. 

8. Attached hereto as Exhibit 6B is a true and correct copy of the patent assignment 

record corresponding to Reel/Frame 044000/0136 through 044000/0290, produced by WSOU in 

this litigation at Bates WSOU-MICAL-0001798-1952.

9. Attached hereto as Exhibit 6C is a true and correct copy of excerpts of the Patent 

Purchase Agreement between Alcatel Lucent, Nokia Solutions and Networks BV, and Nokia 

Technologies Oy, and Wade and Company, dated July 22, 2017. The document was produced by 

WSOU in this litigation at Bates WSOU-MICAL-0000025-44, 246-248, 398-400, 406-408, 468, 

483-502. The document was excerpted to omit the voluminous patent lists attached to the 

Case 6:20-cv-00458-ADA Document 72-1 Filed 09/03/21 Page 2 of 3
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agreement schedules.

10. Attached hereto as Exhibit 6D is a true and correct copy of excerpts of the 

Amendment to the Patent Purchase Agreement, between Alcatel Lucent, Nokia Solutions and 

Networks BV, and Nokia Technologies Oy, and Wade and Company, dated August 2, 2017. The 

document was produced by WSOU in this litigation at Bates WSOU-MICAL-0000503-507, 709-

712, 862-864, 870-872. The document was excerpted to omit the voluminous patent lists 

attached to the agreement schedules.

11. Attached hereto as Exhibit 7 is a true and correct copy of excerpts of the Local 

Rules from United States District Court, Central District of California, as retrieved from 

https://www.cacd.uscourts.gov/sites/default/files/documents/LocalRules_Chap1_12_20.pdf, on 

September 3, 2021.

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

foregoing is true and correct. 

Executed on September 3, 2021 in San Francisco, CA.

/s/ Irene Yang

Irene Yang

Case 6:20-cv-00458-ADA Document 72-1 Filed 09/03/21 Page 3 of 3