Free Affidavit - District Court of Delaware - Delaware

Case 1:04—cv—01338-JJF Document 435 Filed 05/15/2006 Page 1 of 4
UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
HONEYWELL INTERNATIONAL INC. and
HONEYWELL INTELLECTUAL PROPERTIES C.A. No. 04-1338 (KAJ)
INC.,
Plaintiffs,
v.
APPLE COMPUTER, INC., etal.,
Defendants.
AFFIDAVIT OF MICHAEL D. OKERLUND IN SUPPORT OF HONEYWELL’S
MOTION FOR LEAVE TO FILE SUR REPLY IN OPPOSITION TO ARIMA
DISPLAY’S MOTION TO DISIVHSS FOR LACK OF PERSONAL J URISDICTION
STATE OF MINNESOTA )
) ss
COUNTY OF HENNEPIN )
I, Michael D. Okerlund, do hereby declare and state as follows:
1. I am one of the attorneys representing the Plaintiffs in this matter. I am
submitting this Affidavit in Support of Honeywell’s Motion for Leave to File Sur Reply in
Opposition to Arima Display’s Motion to Dismiss for Lack of Personal Jurisdiction. I believe
that the documents attached to this Affidavit as Exhibits A — L are tme and accurate copies of
what they purport to be.
2. Attached as Exhibit A is a true and correct copy of Honeywell’s Sur Reply to
Arima Display’s Motion to Dismiss for Lack of Personal Jurisdiction.
3. Attached as Exhibit B is a mic and correct copy of excerpts from the May 4, 2006
Motions Hearing before this Court.
l
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Case 1:04—cv—01338-JJF Document 435 Filed 05/15/2006 Page 2 of 4
4. Attached as Exhibit C is a true and correct copy of a May 8, 2006 letter from
Honeywell’s counsel, Matthew L. Woods, to Arima Display’s Counsel, Dan C. Hu.
5. Attached as Exhibit D is a true and correct copy of a May 9, 2006 letter from
Arima Display’s counsel, Dan C. Hu, to Honeywell’s counsel, Matthew L. Woods.
6. Attached as Exhibit E is a true and correct copy of the Supplemental Declaration
of Hsing—Hung Shen in Support of Arima Display Corp.’s Motion to Dismiss for Lack of
Personal Jurisdiction, filed on April 17, 2006.
7. Attached as Exhibit F is a true and correct copy of Zebra Technologies
Corporation’s "Investor FAQs," which was located on the world wide web at:
www.zebra.corn/id/zebra/na/en/index/about_zebra/investor_relations/investor_faqs_glossary/inv
estor_faqs.html#FA(L00O5. ·
8. Attached as Exhibit G is a true and correct copy of a webpage published by
Delaware’s Secretary of State, listing the legal status of Zebra Technologies Corporation.
9. Attached as Exhibit H is a true and correct copy of a webpage published by
Delaware’s Secretary of State listing the legal status of Silicon Motion International, Inc.
l0. Attached as Exhibit I is a true and correct copy of a webpage published by AZ
Displays, Inc., which can be located on the world wide web at: www.azo—store.con1/newlcd/.
V ll. Attached as Exhibit J is a true and correct copy of a webpage published by AZ
Displays, Inc., listing AZ Display’s Sales Representative for Delaware, which was located on the
world wide web at: www.azo-store.com/newlcd/extemlink.php3?sesid=A;ZTZV3LYRQWWD5
5XKUO&link=http://www.azdisplays.com.
l2. Attached as Exhibit K is a true and correct copy of a webpage published by AZ
Displays, Inc., listing "Business Opportunities," which was located on the world wide web at:
2
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Case 1 :04-cv-01338-JJF Document 435 Filed 05/15/2006 Page 3 of 4
www.azostore.com/newlcd/extemlir1l<.php3?sesid=A;ZTZV3LYRQWWD55XKUO&link=http:/
/www.azdisplays.com.
13. Attached as Exhibit L is a true and correct copy of a webpage published by
Delaware’s Secretary of State, listing the legal status of Trade Management Solutions LLP.
Further, affiant sayeth not.
Michael D. Okerlund
Subscribed and sworn to before me
t ' 15th day of May, 2006.
Notary Public
BEVERLEE M. DAMYANOVICH
NOT/\RYPlJBl.IC·M1NNESOTA
~< ;_; _;=‘ MY COMMISSION EXPIRES 1·31·10
3
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Case 1:04—cv—01338-JJF Document 435 Filed 05/15/2006 Page 4 of 4
CERTIFICATE OF SERVICE
I hereby certify that on May 15, 2006, I electronically filed the foregoing
document with the Clerk of Court using CM/ECF, which will send notification of such filing to
the following: John R. Alison, Parker H. Bagley, Robert J. Benson, Robert Karl Beste, III,
Elizabeth L. Brarm, John M. Caracappa, Christopher E. Chalsen, Arthur G. Conr1olly, III,
Frederick L. Cottrell, III, Francis DiGiovarmi, Thomas M. Dunham, Amy Elizabeth Evans, York
M. Faulkner, Christopher J. Gaspar, Alexander E. Gasser, Alan M. Grimaldi, Thomas C. Grimm,
Thomas Lee Halkowski, Richard L. Horwitz, Dan C. Hu, John T. Johnson, Robert J.
Katzenstein, Nelson M. Kee, Richard D. Kelly, Stephen S. Korniczky, Hamilton Loeb, Robert
Maier, David J. Margules, David Ellis Moore, Carolyn E. Morris, Arthur I. Neustadt, Elizabeth
A. Niemeyer, Kevin M. O’Brien, Gerard M. O’Rourke, Andrew M. Ollis, Karen L. Pascale,
Adam Wyatt Poff, Leslie A. Polizoti, Alana A. Prills, Steven J. Rizzi, Avelyn M. Ross, Philip A.
Rovner, Diana M. Sangelli, Robert C. Scheinfeld, Carl E. Schlier, John M. Seaman, Chad
Michael Shandler, John W. Shaw, Neil P. Sirota, Monte Terrell Squire, William J. Wade,
Roderick B. Williams and Edward R. Yoches.
I also certify that on May 15, 2006, I caused to be served true and correct copies
of the foregoing on the following as indicated:
BY HAND: BY FEDERAL EXPRESS:
William J. Wade Dan C. Hu
RICHARDS LAYTON & FINGER TROP PRUNER & HU, P.C.
One Rodney Square, P.O. Box 551 8554 Katy Freeway
Wilmington, DE 19899-0551 Houston, TX 77024-1834
6/%»»W 0%
Thomas C. Grim (#1098)
tgrimm @mnat.com