11314360.1 03 

IN THE UNITED STATES DISTRICT COURT 

FOR THE EASTERN DISTRICT OF TEXAS 

MARSHALL DIVISION 

ASUS TECHNOLOGY LICENSING INC. 

AND CELERITY IP, LLC,

 Plaintiffs, 

 v. 

SAMSUNG ELECTRONICS CO., LTD., 

SAMSUNG ELECTRONICS AMERICA, INC., 

AND SAMSUNG RESEARCH AMERICA, 

 Defendants. 

 

Civil Action No. 2:23-cv-409 

JURY TRIAL DEMANDED 

SAMSUNG ELECTRONICS CO., LTD., 

SAMSUNG ELECTRONICS AMERICA, INC., 

AND SAMSUNG RESEARCH AMERICA,

 Counterclaim-Plaintiffs, 

 v. 

ASUS TECHNOLOGY LICENSING INC., 

CELERITY IP, LLC, AND ASUSTEK 

COMPUTER, INC. 

 Counterclaim-Defendants. 

DECLARATION OF REBECCA CARSON IN SUPPORT OF PLAINTIFFS' MOTION 

TO DISMISS AND/OR SEVER COUNTERCLAIMS AGAINST ASUSTEK 

 

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11314360.1 03 - 1 - 

DECLARATION OF REBECCA CARSON 

I, Rebecca Carson, declare as follows: 

1. I am an attorney at the law firm of Irell & Manella LLP, counsel for Plaintiffs ASUS 

Technology Licensing Inc., and Celerity IP, LLC. I am a member in good standing of the State Bar 

of California and have been duly licensed to practice law before all of the courts of the State of 

California, and have been admitted to practice pro hac vice before this Court. I have personal 

knowledge of the matters set forth in this declaration and, if called as a witness, could testify to its 

contents. 

2. Attached as Exhibit A is a true and correct copy of the Patent Assignment Agreement 

assigning U.S. Patent No. 10,187,878 from ASUSTeK Computer Inc., to ASUS Technology 

Licensing Inc., Reel/Frame 064796/0331. 

3. Attached as Exhibit B is a true and correct copy of the Patent Assignment Agreement 

assigning, among others, U.S. Patent No. 11,291,052 from ASUSTeK Computer Inc., to ASUS 

Technology Licensing Inc., Reel/Frame 066711/0278. 

4. Attached as Exhibit C is a true and correct copy of the Patent Assignment Agreement 

assigning U.S. Patent No. 10,104,658 from ASUSTeK Computer Inc., to ASUS Technology 

Licensing Inc., Reel/Frame 065957/0032. 

5. Attached as Exhibit D is a true and correct copy of the Patent Assignment Agreement 

assigning, among others, U.S. Patent No. 10,785,759 from ASUSTeK Computer Inc., to ASUS 

Technology Licensing Inc., Reel/Frame 064788/0882. 

6. Attached as Exhibit E is a true and correct copy of the Patent Assignment Agreement 

assigning, among others, U.S. Patent No. 10,986,585 from ASUSTeK Computer Inc., to ASUS 

Technology Licensing Inc., Reel/Frame 065965/0875. 

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7. Attached as Exhibit F is a true and correct copy of Samsung's Infringement Contentions, 

served March 11, 2024. 

Executed on April 2, 2024. I declare under penalty of perjury that the foregoing is to the best 

of my knowledge and belief. 

By: /s/ Rebecca Carson Rebecca Carson 

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CERTIFICATE OF SERVICE 

I hereby certify that a true and correct copy of the above and foregoing document has been 

served on all counsel of record via email on [date]. 

/s/ DRAFT 

DRAFT 

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