FLIR Systems, Inc. et al v. Edward Huang

Filing 16

PERMANENT INJUNCTION AND DISMISSAL WITH PREJUDICE by Judge Dale S. Fischer. (MD JS-6. Case Terminated.) (SEE PERMANENT INJUNCTION FOR SPECIFICS). (jp)

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JS-6 DSF /s/ Bryan Wilson EXHIBIT BRYAN WILSON (BAR NO. 138842) BWilson@mofo.com ALBERT RUGO (BAR NO. 306134) ARugo@mofo.com MORRISON & FOERSTER LLP 755 Page Mill Road Palo Alto, California 94304-1018 Telephone: 650.813.5600 Facsimile: 650.494.0792 WENDY J. RAY (CA SBN 226269) WRay@mofo.com MORRISON & FOERSTER LLP 707 Wilshire Boulevard Suite 6000 Los Angeles CA 90017-3543 Telephone: (213) 892-5200 Facsimile: (213) 892-5454 Attorneys for Plaintiffs FLIR SYSTEMS, INC. AND FLIR COMMERCIAL SYSTEMS, INC. UNITED STATES DISTRICT COURT CENTRAL DISTRICT OF CALIFORNIA WESTERN DIVISION FLIR SYSTEMS, INC. AND FLIR COMMERCIAL SYSTEMS, INC., Plaintiffs, Case No. 2:19-cv-08510 DSF DECLARATION OF ED HUANG v. EDWARD HUANG, Defendant. FLIR Systems, Inc., et al. v. Edward Huang Case No. 2:19-cv-08510-CAS-KS 1 I, Ed Huang, hereby declare as follows: 1. My name is Ed Huang. I am over twenty-one years of age. I am competent to make this declaration. I have personal knowledge of the facts stated in this declaration and if called upon by a court of law to do so, I could and would testify competently to them. 2. I make this Declaration in connection with the Stipulated Permanent Injunction with FLIR in this matter as entered by the Court. 3. I worked at FLIR Systems, Inc. at 6769 Hollister Ave, Goleta, CA 93117 from October 6, 2014 and January 31, 2019. 4. On or about April 2, 2019, at FLIR’s request and through a mutually established Forensic Inspection Protocol agreement, I voluntarily and personally delivered a number of electronic devices to FLIR through a forensic vendor, Stroz Friedberg. Attached as Exhibit A is a complete and accurate inventory of the electronic devices that I delivered to FLIR. These electronic devices were forensically examined by a third-party vendor retained by FLIR and under FLIR’s direction to identify any FLIR confidential or proprietary information. FLIR represents that the forensic inspection of these electronic devices revealed the presence of FLIR confidential or proprietary information. I accept that representation for purposes of this Declaration. To the best of my knowledge, I do not currently have any FLIR confidential or proprietary information in my possession. Nonetheless, if I subsequently discover any such information, I agree to permanently delete all FLIR confidential or proprietary information from any other electronic devices that are in my possession. 5. I hereby confirm that to the best of my knowledge I have either returned to FLIR, destroyed, or allowed FLIR to destroy any and all FLIR confidential or proprietary information in my possession, regardless of the way in which it was acquired, including but not limited to the following, to the extent they were in my possession: FLIR Systems, Inc., et al. v. Edward Huang Case No. 2:19-cv-08510-CAS-KS 2 Detailed design files of FLIR’s products and components, including optimal design parameters; Detailed simulation and modeling data of FLIR’s products; Purchase orders containing detailed information of FLIR’s ordered parts and components, vendors, and pricing information; Various manufacturing processes and recipe information for FLIR’s products; Detailed packaging and trade study information; and Special and proprietary software tool designed by FLIR. 6. To the best of my knowledge, I no longer possess any of the FLIR confidential or proprietary information in any form whatsoever, whether electronic, hard-copy or in any other respect. In the event that I locate any additional FLIR confidential or proprietary information that I inadvertently failed to return or delete, I agree to return or delete it immediately. 7. I agree that I will not use any FLIR confidential or proprietary information, regardless of the means by which it was acquired. This would include, but is not limited to, the information that was located on my personal devices. 8. I agree that I will provide reasonable assistance and cooperation with any further investigation that may be requested by FLIR, in the event that further investigation is necessary. 9. I hereby also confirm that I have not disclosed any FLIR confidential or proprietary information, including the information listed above, to any thirdparties without FLIR’s authorization. FLIR Systems, Inc., et al. v. Edward Huang Case No. 2:19-cv-08510-CAS-KS 3 I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed in _______________, California this _____ day of October, 2019. Ed Huang FLIR Systems, Inc., et al. v. Edward Huang Case No. 2:19-cv-08510-CAS-KS 4 EXHIBIT DSF

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