Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc. et al

Filing 189

Declaration of BRIAN C. CANNON in support of 190 RESPONSIVE CLAIM CONSTRUCTION BRIEF filed by Roche Molecular Systems, Inc., Roche Diagnostics Corporation, Roche Diagnostics Operations, Inc.. (Attachments: # 1 Exhibit A# 2 Exhibit B# 3 Exhibit C# 4 Exhibit D# 5 Exhibit E# 6 Exhibit F# 7 Exhibit G# 8 Exhibit H# 9 Exhibit I# 10 Exhibit J# 11 Exhibit K)(Cannon, Brian) (Filed on 8/29/2007) Modified on 9/6/2007 (gba, COURT STAFF).

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Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc. et al Doc. 189 Case 3:05-cv-04158-MHP Document 189 Filed 08/29/2007 Page 1 of 2 1 PRUETZ LAW GROUP LLP Adrian M. Pruetz (Bar No. 118215) 2 ampruetz@pruetzlaw.com 1600 Rosecrans Avenue, 4th Floor 3 Manhattan Beach, CA 90266 Telephone: (310) 321-7640 4 Facsimile: (310) 321-7641 5 QUINN EMANUEL URQUHART OLIVER & HEDGES, LLP Brian C. Cannon (Bar No. 193071) 6 briancannon@quinnemanuel.com Tun-Jen Chiang (Bar No. 235165) 7 tjchiang@quinnemanuel.co m 555 Twin Dolphin Drive, Suite 560 8 Redwood Shores, California 94065-2139 Telephone: (650) 801-5000 9 Facsimile: (650) 801-5100 10 Attorneys for Defendants and Counterclaimants Roche Molecular Systems, Inc.; Roche Diagnostics 11 Corporation; and Roche Diagnostics Operations, Inc. 12 13 UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA CASE NO. C-05-04158 MHP DECLARATION OF BRIAN C. CANNON IN SUPPORT OF ROCHE'S: RESPONSIVE CLAIM CONSTRUCTION BRIEF [PATENT LOCAL RULE 4-5(b)] Judge: Hon. Marilyn H. Patel Date: October 3, 2007 Time: Ctrm: 15, 18th Floor 14 THE BOARD OF TRUSTEES OF THE LELAND STANFORD JUNIOR UNIVERSITY, 15 Plaint iff, 16 vs. 17 ROCHE MOLECULAR SYSTEMS, INC.; 18 ROCHE DIAGNOSTICS CORPORATION; ROCHE DIAGNOSTICS OPERATIONS, INC., 19 Defendants. 20 ROCHE MOLECULAR SYSTEMS, INC. 21 ROCHE DIAGNOSTICS CORPORATION; ROCHE DIAGNOSTICS OPERATIONS, INC., 22 Counterclaimants, 23 vs. 24 THE BOARD OF TRUSTEES OF THE 25 LELAND STANFORD JUNIOR UNIVERSITY; AND THOMAS MERIGAN. 26 Counterclaim Defendants. 27 28 04972/2207327.1 Eugene T. Chen, declare as follows: -1- Case No. 05-CV-04158-MHP DECLARATION OF BRIAN C. CANNON Dockets.Justia.com Case 3:05-cv-04158-MHP Document 189 Filed 08/29/2007 Page 2 of 2 1 2 1. Declaration of Brian C. Cannon I am a member of the Bar of the State of California and a partner with Quinn 3 Emanuel Urquhart Oliver & Hedges, LLP, attorneys for Roche Molecular Systems, Inc, Roche 4 Diagnostics Corporation, and Roche Diagnostics Operations, Inc. ("Roche"). I make this 5 declaration of personal, firsthand knowledge and, if called and sworn as a witness, I could and 6 would testify competently thereto. 7 2. Attached as Exhibit A are selected pages from the August 19, 2007 deposition of 8 Paul Volberding, M.D. 9 3. Attached as Exhibit B are selected pages from the transcript of proceedings before 10 the Court dated July 30, 2007. 11 4. Attached as Exhibit C is the transcript from the scheduled August 15, 2007 12 deposition of Fred Kramer. 13 5. 14 16, 2007. 15 6. 16 7. 17 8. 18 9. 19 10. Attached as Exhibit E is Stanford's May 29, 2007 answer to Interrogatory No. 32. Attached as Exhibit F is U.S. Patent No. 5,968,730. Attached as Exhibit G is U.S. Patent No. 6,503,705. Attached as Exhibit H is U.S. Patent No. 7,129,041. Attached as Exhibit I is a published article, Mark Holodniy, "Clinical Application Attached as Exhibit D is a letter sent by me to counsel for Stanford dated August 20 of Reverse Transcription Polymerase Chain Reaction for HIV Infection," in CLINICS IN 21 LABORATORY MEDICINE, Vol. 14: 335-349 (June 1994). 22 11. 23 24 25 26 27 28 04972/2207327.1 Attached as Exhibit J is Tabers Medical Dictionary, 608 (17th ed. 1993). I declare under penalty of perjury that the foregoing is true and correct. Executed on August 29, 2007, in Redwood Shores, California. ________________/s/_____________________ Brian C. Cannon -2- Case No. 05-CV-04158-MHP DECLARATION OF BRIAN C. CANNON

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