Overture Services, Inc. v. Google Inc.

Filing 193

Declaration of Christine P. Sun in Support of 175 Motion to Compel Production of Documents and Testimony Re Prosecution of the '361 Patent (Publicly Filed Version of Declaration - Without Exhibits) filed by Google Inc.. (Related document(s) 175 ) (Sun, Christine) (Filed on 7/9/2004)

Overture Services, Inc. v. Google Inc.

Doc. 193

Case 3:02-cv-01991-JSW

Document 193

Filed 07/09/2004

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KEKER & VAN NEST, LLP JOHN W. KEKER - #49092 DARALYN J. DURIE - #169825 CHRISTINE P. SUN - #218701 RAVIND S. GREWAL - #220543 710 Sansome Street San Francisco, CA 94111-1704 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant and Counterclaimant GOOGLE INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION

OVERTURE SERVICES, INC., Plaintiff and Counterdefendant, v. GOOGLE INC., Defendant and Counterclaimant.

Case No. C 02-01991 JSW (EDL) DECLARATION OF CHRISTINE P. SUN IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND TESTIMONY RE: PROSECUTION OF `361 PATENT (WITHOUT EXHIBITS) Date: August 10, 2004 Time: 9:00 a.m. Courtroom: 2, 15th Floor Judge: Hon. Elizabeth D. Laporte

PUBLICLY FILED VERSION (WITHOUT EXHIBITS)

334935.01

DECLARATION OF CHRISTINE P. SUN IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND TESTIMONY RE: PROSECUTION OF `361 PATENT (WITHOUT EXHIBITS) CASE NO. C 02-01991 JSW (EDL) Dockets.Justia.com

Case 3:02-cv-01991-JSW

Document 193

Filed 07/09/2004

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I, CHRISTINE P. SUN, declare as follows: 1. I am an attorney licensed to practice in the State of California and am an associate

at the law firm of Keker & Van Nest, LLP, counsel for Defendant and Counterclaimant Google Inc. in this matter. 2. Attached hereto as Exhibit A is a true and correct copy of a document entitled

"February 1998 Goto.com Business Plan," (THD 132-180). 3. Attached hereto as Exhibit B is a true and correct copy of emails that were

attached to a document entitled "March 1998 Goto.com Business Plan," (OVG 47263-47271). 4. Attached hereto as Exhibit C is a true and correct copy of excerpts from the May

20, 2003 deposition of Darren J. Davis, and the errata sheet for that deposition. 5. Attached hereto as Exhibit D is a true and correct copy of excerpts from the July

18, 2003 deposition of Elaine K. Lee. 6. Attached hereto as Exhibit E is a true and correct copy of excerpts from the July

23, 2003 deposition of John Rauch, and the errata sheet for that deposition. 7. Attached hereto as Exhibit F is a true and correct copy of a report entitled "Line

Ad Totals: Clients by Name, May 1998" (OVGE 175429-175448), exhibit 41 from the April 27, 2004 deposition of Overture's 30(b)(6) witness. 8. Attached hereto as Exhibit G is a true and correct copy of a report entitled

"Toyota, May 1998" (OVGE 176844-176847), exhibit 43 from the April 27, 2004 deposition Overture's 30(b)(6) witness. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed this 9th day of July, 2004, at San Francisco, California.

/s/ Christine P. Sun CHRISTINE P. SUN

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334935.01

DECLARATION OF CHRISTINE P. SUN IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF DOCUMENTS AND TESTIMONY RE: PROSECUTION OF `361 PATENT (WITHOUT EXHIBITS) CASE NO. C 02-01991 JSW (EDL)