Netflix, Inc. v. Blockbuster, Inc.

Filing 101

Declaration of Ashok Ramani in Support of 100 Brief Declaration of Ashok Ramani In Support Of Netflix's Opening Claim-Construction Brief filed byNetflix, Inc.. (Attachments: # 1 Exhibit 1# 2 Exhibit 2# 3 Exhibit 3# 4 Exhibit 4# 5 Exhibit 5# 6 Exhibit 6# 7 Exhibit 7.1# 8 Exhibit 7.2# 9 Exhibit 7.3# 10 Exhibit 8# 11 Exhibit 9# 12 Exhibit 10# 13 Exhibit 11# 14 Exhibit 12# 15 Exhibit 13)(Related document(s)100) (Ramani, Ashok) (Filed on 12/6/2006)

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Netflix, Inc. v. Blockbuster, Inc. Doc. 101 Case 3:06-cv-02361-WHA Document 101 Filed 12/06/2006 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 KEKER & VAN NEST, LLP JEFFREY R. CHANIN - #103649 DARALYN J. DURIE - #169825 ASHOK RAMANI - #200020 710 Sansome Street San Francisco, CA 94111-1704 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 Attorneys for Plaintiff NETFLIX, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA NETFLIX, INC., a Delaware corporation, Plaintiff, v. BLOCKBUSTER, INC., a Delaware corporation, DOES 1-50, Defendant. Case No. C 06 2361 WHA (JCS) DECLARATION OF ASHOK RAMANI IN SUPPORT OF NETFLIX'S OPENING CLAIM-CONSTRUCTION BRIEF Date: Time: Dept: Judge: January 31, 2007 TBD Courtroom 9, 19th Floor Hon. William H. Alsup AND RELATED COUNTERCLAIMS 385648.01 RAMANI DECLARATION IN SUPPORT OF NETFLIX'S OPENING CLAIM-CONSTRUCTION BRIEF CASE NO. C 06 2361 WHA (JCS) Dockets.Justia.com Case 3:06-cv-02361-WHA Document 101 Filed 12/06/2006 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 I, ASHOK RAMANI, declare and state as follows: 1. I am an attorney duly licensed to practice before this Court, and am a partner with Keker & Van Nest, LLP, counsel to Plaintiff and Counterclaim-Defendant Netflix, Inc. I have personal knowledge of the facts set forth below, and if called to testify as a witness thereto could do so competently under oath. 2. Attached hereto as Exhibit 1 is a true and correct copy of United States Patent Number 6,584,450, issued June 24, 2003. 3. Attached hereto as Exhibit 2 is a true and correct copy of United States Patent Number 7,024,381, issued April 4, 2006. 4. Attached hereto as Exhibit 3 is a true and correct copy of the Supplemental Declaration of Neil D. Hunt, filed with the United States Patent Office on October 25, 2002 and contained in the U.S. Patent Office's File History for U.S. Patent No. 6,584,450. 5. Attached hereto as Exhibit 4 is a true and correct copy of a press release from Netflix, dated December 16, 1999, filed with the United States Patent Office on October 25, 2002 and contained in the U.S. Patent Office's File History for U.S. Patent No. 6,584,450. 6. Attached hereto as Exhibit 5 is a true and correct copy of Netflix's Letter to the U.S. Patent Examiner, dated October 17, 2002 and contained in the U.S. Patent Office's File History for U.S. Patent No. 7,024,381. 7. Attached hereto as Exhibit 6 is a true and correct copy of the Notice of Allowability, dated December 5, 2005 and contained in the U.S. Patent Office's File History for U.S. Patent No. 7,024,381. 8. Attached hereto as Exhibit 7 is a true and correct copy of Netflix's Amended and Corrected Disclosure of Asserted Claims and Preliminary Infringement Contentions for U.S. Patent Nos. 7,024,381 and 6,584,450, filed with this Court on July 28, 2006 as Docket # 31. 9. Attached hereto as Exhibit 8 is a true and correct copy of a document produced by Blockbuster and bearing the Bates Production Numbers BB00199492-BB00199501. [THIS EXHIBIT HAS BEEN FILED UNDER SEAL]. 10. Attached hereto as Exhibit 9 is a true and correct copy of pages from the 1 385648.01 RAMANI DECLARATION IN SUPPORT OF NETFLIX'S OPENING CLAIM-CONSTRUCTION BRIEF CASE NO. C 06 2361 WHA (JCS) Case 3:06-cv-02361-WHA Document 101 Filed 12/06/2006 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 American Heritage Dictionary of the English Language (4th ed. 2000). 11. Attached hereto as Exhibit 10 is a true and correct copy of pages from the Merriam-Webster's Collegiate Dictionary (11th ed. 2003). 12. Attached hereto as Exhibit 11 is a true and correct copy of a U.S. Patent Office Action communication, dated October 28, 2004 and contained in the U.S. Patent Office's File History for U.S. Patent No. 7,024,381. 13. Attached hereto as Exhibit 12 is a true and correct copy of Netflix's Reply to the U.S. Patent Office Action, dated January 31, 2005 and contained in the U.S. Patent Office's File History for U.S. Patent No. 7,024,381. 14. Attached hereto as Exhibit 13 is a true and correct copy of pages from the Oxford English Dictionary Online (2d ed. 2006), a subscription service found at http://dictionary.oed.com. I declare under penalty of perjury under the laws of the State of California that the foregoing is true and correct. Executed on this 6th day of December 2006, at San Francisco, California. /s/ Ashok Ramani______________ 2 385648.01 RAMANI DECLARATION IN SUPPORT OF NETFLIX'S OPENING CLAIM-CONSTRUCTION BRIEF CASE NO. C 06 2361 WHA (JCS)

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