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IN UNITED STATES DISTRICT COURT 

FOR THE NORTHERN DISTRICT OF TEXAS 

DALLAS DIVISION 

ZT IP, LLC, 

Plaintiff, 

v. 

VMWARE, INC., 

Defendant. 

Case No. 3:22-cv-970 

JURY TRIAL DEMANDED 

DECLARATION OF RICHARD HUNG IN SUPPORT OF DEFENDANT VMWARE, 

INC.’S MOTIONS TO JOIN PARTIES AND TO AMEND THE JUDGMENT 

I, Richard Hung, am a partner with Morrison & Foerster LLP, counsel for VMware, Inc. 

(“VMware”). I make this declaration in support of VMware’s Motions to Join Parties and 

Motion to Amend the Judgment. 

1. Attached as Exhibit 1 is a true and correct copy of ZT IP, LLC’s (“ZT”) 

Certificate of Formation - Limited Liability Company (Form 205), obtained from the Office of 

the Secretary of State of Texas, with a filing date of February 28, 2022. 

2. Attached as Exhibit 2 is a true and correct copy of ZT’s Responses to VMware’s 

Interrogatories, as served on May 14, 2023. 

3. Attached as Exhibit 3 is a true and correct copy of the Certificate of Formation of 

Entente IP LLC, obtained from the Office of the Secretary of State of Delaware, with a filing 

date of May 8, 2020. 

4. Attached as Exhibit 4 is a true and correct copy of the Certificate of Amendment 

to the Certificate of Formation of ZT IP, LLC, dated March 24, 2022. 

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5. Attached as Exhibit 5 is a true and correct copy of the Certificate of Formation of 

Dynamic IP Deals, LLC (“Dynamic IP”), obtained from the Office of the Secretary of State of 

Texas, with a filing date of September 27, 2013. 

6. Attached as Exhibit 6 is a true and correct copy of Pueblo Nuevo LLC (“Pueblo 

Nuevo”) Certificate of Formation – Limited Liability Company (Form 205), filed with the Office 

of the Secretary of the State of Texas, with a filing date of December 30, 2020. 

7. Attached as Exhibit 7 is a true and correct copy of the Texas Franchise Tax 

Public Information Report for Dynamic IP, dated May 16, 2022. 

8. Attached as Exhibit 8 is a true and correct copy of Docket Entry 19 from Missed 

Call, LLC v. Freshworks, Inc., Case No. 1:22-cv-00739-CFC (D. Delaware) (“Missed Call

Litigation”). 

9. Attached as Exhibit 9 is a true and correct copy of the Texas Franchise Tax 

Public Information Report for Pueblo Nuevo, dated May 16, 2022. 

10. Attached as Exhibit 10 is a true and correct copy of Docket Entry 40-10 from 

Silent Communications, LLC v. Blackberry Corp., Case No. 6:22-cv-00252-ADA (W.D. Texas) 

(“Silent Communications Litigation”). 

11. Attached as Exhibit 11 is a true and correct copy of an email chain between 

counsel for VMware and Mr. Ramey, counsel for ZT, between June 13, 2022 and March 8, 2023. 

12. Attached as Exhibit 12 is a true and correct copy of Docket Entry 33 from 

EscapeX IP LLC v. Block, Inc., Case No. 1:22-cv-03575-JMF (S.D. New York). 

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13. Attached as Exhibit 13 is a true and correct copy of a report generated from Lex 

Machina, a litigation research service provided by Lexis, showing the list of cases of ten entities 

owned by or related to Dynamic IP1

 in which Mr. Ramey is counsel of record. 

14. Attached as Exhibit 14 is a true and correct copy of Docket Entry 1 from mCom 

IP, Inc. v. DH Corporation, Case No. 6:21-Cv-00197 (W.D. Texas). 

15. Attached as Exhibit 15 is a true and correct copy of Docket Entry 1 from 

Cybersoft IP, LLC v. Kaspersky Lab, Inc., Case No. 1:21-cv-10704 (D. Massachusetts). 

16. Attached as Exhibit 16 is a true and correct copy of Docket Entry 1 from AML 

IP, LLC v. Stripe, Inc., Case No. 6:22-cv-01257 (W.D. Texas). 

17. Attached as Exhibit 17 is a true and correct copy of Docket Entry 1 from the 

Silent Communications Litigation. 

18. Attached as Exhibit 18 is a true and correct copy of Docket Entry 1 from 

PacSec3, LLC v. Netscout Systems, Inc., Case No. 6:20-cv-00914 (W.D. Texas). 

19. Attached as Exhibit 19 is a true and correct copy of Docket Entry 2 from Datrec, 

LLC v. AllegianceMD Softward, Inc., Case No. 4:21-cv-00543 (N.D. Oklahoma). 

20. Attached as Exhibit 20 is a true and correct copy of Docket Entry 1 from 

AuthWallet, LLC v. CIBC Bank USA, Case No. 6:23-cv-00141 (W.D. Texas). 

21. Attached as Exhibit 21 is a true and correct copy of Docket Entry 1 from Geotag 

IP, LLC v. NXP USA, Inc., Case No. 6:22-cv-00125 (W.D. Texas). 

22. Attached as Exhibit 22 is a true and correct copy of Docket Entry 1 from Gold IP 

LLC v. Augury Inc., Case No. 1:21-cv-04788 (S.D. New York). 

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 The ten entities are PacSec3, LLC; mCom IP, LLC; Cybersoft IP, LLC; AML IP, LLC; 

Silent Communications, LLC; Datrec, LLC; AuthWallet, LLC; GeoTag IP, LLC; Gold IP LLC; 

and Missed Call, LLC. See Mot. to Join at Section II.A.3, Mot. to Amend at Section II.A.3. 

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23. Attached as Exhibit 23 is a true and correct copy of Docket Entry 34 in the 

Missed Call Litigation. 

24. Attached as Exhibit 24 is a true and correct copy of Docket Entry 14 from Safe IP 

LLC v. Proctorio, Inc., Case No. 1:22-cv-920-CFC (D. Delaware). 

25. Attached as Exhibit 25 is a true and correct copy of the March, April, May and 

June, 20232

 invoices from Morrison & Foerster LLP to VMware showing $40,528.85 in attorney 

fees. These documents contain confidential information and are filed under seal. Certain 

Taxpayer ID and Account information has been redacted from this Exhibit. 

26. Attached as Exhibit 26 is a true and correct copy of an email chain between 

counsel for VMware and Mr. Norred, counsel for ZT, between May 5 and June 5, 2023 

27. Attached as Exhibit 27 is a true and correct copy of Docket Entry 29 from the 

Missed Call Litigation. 

I declare under penalty of perjury that the foregoing is true and correct. 

Dated: August 11, 2023 

/s/ Richard Hung 

Richard S.J. Hung, (Bar No. 43684) 

RHung@mofo.com 

425 Market Street 

San Francisco, CA 94105-2482 

Telephone: 415.268.7000 

Facsimile: 415.268.7522 

Attorney for Defendant 

 

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 Additional fees incurred for July 2023 forward have been incurred but, because they 

have not yet been billed to VMware, they are not included here. Additional invoices may be 

submitted if and when one or more Responsible Parties are joined to this action. 

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CERTIFICATE OF SERVICE 

The undersigned counsel for VMware, Inc. hereby certifies that a true and correct copy of 

this motion is being served on the following individuals and entities as soon as practicable, via 

personal service, and that VMWare, Inc. will file proof of service once received from VMWare, 

Inc.’s process server which will show the actual date(s) of service: 

Dynamic IP Deals, LLC 

5900 Balcones Dr, Ste 100 

Austin, TX 78731 

Pueblo Nuevo LLC 

5900 Balcones Dr, Ste 100 

Austin, TX 78731 

Entente IP LLC 

Harvard Business Services, inc. 

16192 Coastal Hwy 

Lewes, DE 19958 

Ramey LLP 

5020 Montrose Blvd., Ste 800 

Houston, TX 77006 

Carlos Gorrichategui 

8319 Barberry Branch Street 

Houston, TX 77055 

David Ghorbanpoor 

756 E. Lexington Blvd. 

Milwaukee, WI 53217 

William P. Ramey III 

5020 Montrose Blvd., Ste 800 

Houston, TX 77006 

The undersigned counsel also hereby certifies that, on August 11, 2023, the foregoing 

document was filed via the Court’s ECF system, which will send notice of the filing to counsel 

for Plaintiff. 

/s/ Richard S.J. Hung 

Richard S.J. Hung 

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