IO Group, Inc. v. Veoh Networks, Inc.

Filing 80

Declaration of Gill Sperlein in Support of Plaintiff's Motion for Summary Judgment on Liability re 78 filed by IO Group, Inc. (Attachments: # 1 Exhibit Papa Declaration Excerpts# 2 Papa Deposition Ex. #3# 3 Papa Deposition Ex. #11# 4 Papa Deposition Ex. #16# 5 Dunning Deposition Excerpts# 6 Shapiro Deposition Excerpts# 7 Shapiro Deposition Ex. #5# 8 Styn Deposition Excerpts# 9 Bilger Deposition Excerpts)(Related document(s) 78 ) (Sperlein, Dennis) (Filed on 7/31/2007) Text modified on 8/7/2007 to conform to document caption post by counsel (bw, COURT STAFF).

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IO Group, Inc. v. Veoh Networks, Inc. Doc. 80 Case 5:06-cv-03926-HRL Document 80 Filed 07/31/2007 Page 1 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 GILL SPERLEIN (172887) THE LAW FIRM OF GILL SPERLEIN 584 Castro Street, Suite 849 San Francisco, California 94114 Telephone: (415) 487-1211 X32 Facsimile: (415) 252-7747 legal@titanmedia.com Attorney for Plaintiff IO GROUP, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION IO GROUP, INC., a California corporation, Plaintiff, vs. VEOH NETWORKS, Inc., a California Corporation, Defendant. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) C-06-03926 (HRL) DECLARATION OF GILL SPERLEIN IN SUPPORT OF PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT ON LIABILITY DATE: April 10, 2007 TIME: 10:00 a.m. COURTROOM: 2 I, GILL SPERLEIN, declare: 1. I am an attorney at law licensed to practice in the State of California and attorney of record for Plaintiff Io Group, Inc. 2. Attached hereto as Exhibit A is a true and correct copy of the relevant excerpted pages of the deposition transcript of Defendant Veoh Network's Director of Product Development, Joseph Papa, who testified on behalf of Defendant Veoh Networks, Inc. under F.R.C.P. 30(b)(6). The excerpted deposition pages accurately reflect the questions asked and the answers given -1SPERLEIN DECLARATION IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT C-06-3926 (HRL) Dockets.Justia.com Case 5:06-cv-03926-HRL Document 80 Filed 07/31/2007 Page 2 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 during depositions which I took on May 21 and 22, 2007, in San Diego, California. Defendant's deposition was reported by Nicole R. Harnish, RPR, CSR No. 13101. a. Attached hereto as Exhibit B is a true and correct copy of Exhibit 3 to the Defendant's deposition; b. Attached hereto as Exhibit C is a true and correct copy of Exhibit 11 to the Defendant's deposition; c. Attached hereto as Exhibit D is a true and correct copy of Exhibit 16 to the Defendant's deposition. 3. Attached hereto as Exhibit E is a true and correct copy of the relevant excerpted pages of the deposition transcript of Defendant Veoh Network's Chief Scientific Officer, Dr. Ted Dunning ("Dunning"). The excerpted deposition pages accurately reflect the questions asked and the answers given during the Dunning deposition which I took on March 16, 2007, in San Diego, California. Dr. Dunning's deposition was reported by Rita Burgess, RPR, CSR No. 8374. 4. Attached hereto as Exhibit F is a true and correct copy of the relevant excerpted pages of the deposition transcript of Defendant Veoh Network's Chief Executive Officer, Dmitry Shapiro ("Shapiro") who testified on behalf of Veoh Networks under F.R.C.P. 30(b)(6). The excerpted deposition pages accurately reflect the questions asked and the answers given during the Shapiro deposition which I took on May 21, in San Diego, California. Mr. Shapiro's deposition was reported by Nicole R. Harnish, RPR, CSR No. 13101. a. Shapiro deposition. 5. Attached hereto as Exhibit H is a true and correct copy of the relevant excerpted Attached hereto as Exhibit G is a true and correct copy of Exhibit 5 to the pages of the deposition transcript of Mr. John Styn ("Styn") a paid consultant of Defendant Veoh -2SPERLEIN DECLARATION IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT C-06-3926 (HRL) Case 5:06-cv-03926-HRL Document 80 Filed 07/31/2007 Page 3 of 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Network. The excerpted deposition pages accurately reflect the questions asked and the answers given during the Styn deposition which I took on May 31, in San Diego, California. Mr. Styn's deposition was reported by Regina L. Garrison, RPR, CSR No. 12921. 6. Attached hereto as Exhibit I is a true and correct copy of the relevant excerpted pages of the deposition transcript of Mr. Arthur Bilger ("Bilger"), who testified on behalf of Shelter Capital Partners, LLC, under F.R.C.P. 30(b)(6). The excerpted deposition pages accurately reflect the questions asked and the answers given during the Bilger deposition which I took on June 5, 2007, in El Segundo, California. Mr. Bilger's deposition was reported by Chia Mei Jui, RPR, CSR No. 3287. Pursuant to the laws of the United States, I declare under penalty of perjury the foregoing is true and correct. Dated: July 31, 2007 /s/ Gill Sperlein ____________________ GILL SPERLEIN, Attorney for Plaintiff -3SPERLEIN DECLARATION IN SUPPORT OF MOTION FOR SUMMARY JUDGMENT C-06-3926 (HRL)