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

Filing 192

SUPPLEMENTAL Declaration of Michelle S. Rhyu in Support of 191 Reply to 190 Roche's Responsive Claim Construction Brief filed by Board of Trustees of the Leland Stanford Junior University. (Attachments: # 1 Exhibit 17# 2 Exhibit 19# 3 Exhibit 24# 4 Exhibit 26# 5 Exhibit 27# 6 Exhibit 28# 7 Exhibit 29# 8 Exhibit 30# 9 Exhibit 31# 10 Exhibit 32# 11 Exhibit 33)(Related document(s)191) (Rhyu, Michelle) (Filed on 9/12/2007) Modified on 9/19/2007 (gba, COURT STAFF).

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Board of Trustees of the Leland Stanford Junior University v. Roche Molecular Systems, Inc. et al Doc. 192 Case 3:05-cv-04158-MHP Document 192 Filed 09/12/2007 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 COOLEY GODWARD KRONISH LLP ATTORNEYS AT LAW PALO ALTO COOLEY GODWARD KRONISH LLP STEPHEN C. NEAL (No. 170085) (nealsc@cooley.com) RICARDO RODRIGUEZ (No. 173003) (rr@cooley.com) MICHELLE S. RHYU (No. 212922) (mrhyu@cooley.com) Five Palo Alto Square 3000 El Camino Real Palo Alto, CA 94306-2155 Tel: (650) 843-5000 Fax: (650) 857-0663 Attorneys for Plaintiff and Counterclaim Defendant, THE BOARD OF TRUSTEES OF THE LELAND STANFORD JUNIOR UNIVERSITY and Counterclaim Defendants THOMAS MERIGAN and MARK HOLODNIY UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA THE BOARD OF TRUSTEES OF THE LELAND STANFORD JUNIOR UNIVERSITY, Plaintiff, v. ROCHE MOLECULAR SYSTEMS, ET AL., Defendants. ROCHE MOLECULAR SYSTEMS, ET AL., Counterclaimants, v. THE BOARD OF TRUSTEES OF THE LELAND STANFORD JUNIOR UNIVERSITY; THOMAS MERIGAN; AND MARK HOLODNIY, Counterclaim Defendants. Case No. C 05 04158 MHP SUPPLEMENTAL DECLARATION OF MICHELLE S. RHYU IN SUPPORT OF STANFORD'S REPLY TO ROCHE'S RESPONSIVE CLAIM CONSTRUCTION BRIEF 759490 v1/PA SUPP. RHYU DECL. ISO STANFORD'S CLAIM CONST. REPLY BRIEF CASE NO. C 05 04158 MHP Dockets.Justia.com Case 3:05-cv-04158-MHP Document 192 Filed 09/12/2007 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 COOLEY GODWARD KRONISH LLP ATTORNEYS AT LAW PALO ALTO I, Michelle S. Rhyu, declare as follows: 1. I am an attorney with the law firm of Cooley Godward Kronish LLP, counsel of record for The Board of Trustees of the Leland Stanford Junior University, Thomas Merigan and Mark Holodniy in the above-captioned matter. I have knowledge of the following, and if called as a witness, I could and would testify competently to this declaration's contents. 2. Attached hereto as Revised Exhibit 17 are true and correct copies of excerpts from Webster's Medical Desk Dictionary (1986), bearing Bates numbers STAN 031809, STAN 031810, STAN 031811, STAN 031814, STAN 031815 and STAN 031816. Revised Exhibit 17 adds STAN 031816, which was inadvertently omitted from the original Exhibit 17 filed with the Declaration of Michelle S. Rhyu Supporting Stanford's Opening Claim Construction Brief. 3. Attached hereto as Exhibit 26 are true and correct copies of excerpts from the Deposition of Paul Volberding, M.D., conducted on August 19, 2007. 4. Attached hereto as Exhibit 27 are true and correct copies of excerpts from the Deposition of John G. Bartlett, M.D., conducted on September 5, 2007. Due to the late timing of the deposition, the copies are from the electronic version of the deposition. 5. Attached hereto as Exhibit 28 are true and correct copies of excerpts from the Deposition of Jeffrey David Lifson, M.D., conducted on September 5, 2007. Due to the late timing of the deposition, the copies are from the electronic version of the deposition. 6. Attached hereto as Exhibit 29 are true and correct copies of excerpts from the Deposition of Alice Wang, Ph.D., conducted on August 8, 2007. 7. Attached hereto as Exhibit 30 is a true and correct copy of Stanford University's Disclosure of Asserted Claims and Preliminary Infringement Contentions and Document Production Accompanying Disclosure, dated February 28, 2006. 8. Attached hereto as Exhibit 31 is a true and correct copy of Stanford's Second Amended Disclosure of Asserted Claims and Preliminary Infringement Contentions and Supplemental Document Production, dated July 10, 2007. 9. Attached hereto as Exhibit 32 is a true and correct copy of an email from Ricardo Rodriguez to Brian Cannon dated August 13, 2007. 759490 v1/PA 1. SUPP. RHYU DECL. ISO STANFORD'S CLAIM CONST. REPLY BRIEF CASE NO. C 05 04158 MHP Case 3:05-cv-04158-MHP Document 192 Filed 09/12/2007 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 COOLEY GODWARD KRONISH LLP ATTORNEYS AT LAW PALO ALTO 10. Attached hereto as Exhibit 33 is a true and correct copy of Stanford's Disclosure of Asserted Claims and Preliminary Infringement Contentions and Supplemental Document Production, dated April 13, 2007. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct, and that this declaration was executed at Palo Alto, California on September 12, 2007. /s/ Michelle S. Rhyu 759490 v1/PA 2. SUPP. RHYU DECL. ISO STANFORD'S CLAIM CONST. REPLY BRIEF CASE NO. C 05 04158 MHP

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