Free Affidavit - District Court of Delaware - Delaware

Case 1 :04-cv-01338-JJF Document 386-2 Filed O4/06/2006 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., et al.,
Defendants.
AFFIDAVIT OF MICHAEL D. OKERLUND IN SUPPORT OF HONEYWELL’S
OPPOSITION TO DEFENDANT ARIMA DISPLAY’S MOTION TO DISMISS FOR
LACK OF PERSONAL JURISDICTION
STATE OF MINNESOTA )
) ss
COUNTY OF HENNEPIN )
I, Michael D. Okerlund, do hereby declare and state as follows:
l. I am one of the attomeys representing the Plaintiffs in this matter. I am
submitting this Affidavit in Support of Honeywell’s Opposition to Defendant Aiima Display’s
Motion to Dismiss for Lack of Personal Jtuisdiction. I believe that the documents attached to
this Affidavit as Exhibits A — H are true and accurate copies of what they purport to be.
2. Attached as Exhibit A is a true and correct copy of a “Welcome" page on Arima
Computer Corporation’s website, located at: http://www.anma.com.twN/.
3. Attached as Exhibit B is a true and correct copy of another version of the
"Welcome" page on Arima Computer Corporation’s website, which presents different pictures of
various LCD devices as well as electronic links to information concerning those devices.
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Clicking on the links marked "Mainstream Performance Value Line," and "LCD PC, LCD TV,"
transports the user to pages two and three of Exhibit B, both of which are also located at:
http://www.arima.com.tw/,
4. Attached as Exhibit C is a true and correct copy of an internet page containing
information concerning the "Arima" family of companies, which include Arima
Communications, Arima Display, and Arima Computer Corporation. That website is located at:
http://www.arima.com.tx>v/about_group.htm. Following the electronic link under Arima
Computer will lead the user to information concerning Arima Computer’s LCD products, which
include the 27" LCD TV, advertised on pages two and three of Exhibit C.
5. Attached as Exhibit D is a true and correct copy of a website page on Arima
Computer Corporation’s website, with the headlines "Wh0 We Are," and "Where We D0
Business." Page two of Exhibit D provides information concerning Arima Computer
Corporation’s factory and service center, located in Houston, Texas. Exhibit D is located at:
http1//www.arima.com.tw/about_aboutarima.ht1n.
6. Attached as Exhibit E is a true and correct copy of Arirna Display’s English
website listing a "Company Proiile," located at: http;//www.arimadisp.com/EN/about/mainhtm.
7. Attached as Exhibit F is a true and correct copy of a webpage that can be located
on Aiima Display’s website at: http://wvvvv.a1rima.com.txv/ by following the link at the top of the
page named "On-line Request For Quotation."
8. Attached as Exhibit G is a true and correct copy of an email page that is
automatically generated when a user visits Arima Display’s website, located at:
http:/Mi>vw.arima.com.tw/. (see Exhibit E, supra), and clicks on the link labeled "Contact Us."
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9. Attached as Exhibit H is a true and correct copy of a receipt from US Tronics, an
online electronics retailer, listing a number of products purchased by Honeywell, including one
Sony Ericsson “Z200 GSM World Phone" which was "tom down" by Honeywell employees and
found to contain a LCD module manufactured by Arima Display.
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Further, affiant sayeth not.
Michael D. Okerlund
Subscribed and sworn to before me
s 6th day of April, 2006.
Notary Pu lic
S BEVERLEE M. DAMYANOVICH
NOTAHY PUBUC-MINNESOTA
WOOMWSSION EXHRES1-31-10
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CERTIFICATE OF SERVICE
I hereby certify that on April 6, 2006, I electronically tiled the foregoing
document with the Clerk of Court using CM/ECP, which will send notification of such tiling to
the following: John R. Alison, Parker I-I. Bagley, Robert J. Benson, Robert Karl Beste, III,
Elizabeth L. Brann, John M. Caracappa, Christopher E. Chalsen, Arthur G. Connolly, III,
Frederick L. Cottrell, III, Francis DiGiovanni, 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. Komiczky, 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 April 6, 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. I-Iu
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—l834
/s/Leslie A. Polizoti

lpoli:[email protected]
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