Netlist, Inc. v. Google Inc.

Filing 48

CLAIM CONSTRUCTION STATEMENT filed by Netlist, Inc.. (Attachments: # 1 Declaration of Steven R. Hansen in Support of Plaintiff Netlist, Inc.'s Opening Claim Construction Brief, # 2 Exhibit A to Decl. of Steven R. Hansen, # 3 Exhibits B - G to Decl. of Steven R. Hansen)(Hansen, Steven) (Filed on 7/16/2010)

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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 PRUETZ LAW GROUP LLP Adrian M. Pruetz (Bar No. 118215) ampruetz@pruetzlaw.com Erica J. Pruetz (Bar No. 227712) ejpruetz@pruetzlaw.com 200 N. Sepulveda Blvd., Suite 1525 El Segundo, CA 90245 Phone: 310.765.7650 Fax: 310.765.7641 LEE TRAN & LIANG APLC Enoch H. Liang (Bar No. 212324) ehl@ltlcounsel.com Steven R. Hansen (Bar No. 198401) srh@ltlcounsel.com 601 S. Figueroa Street, Suite 4025 Los Angeles, CA 90017 Phone: 213.612.3737 Fax: 213.612.3773 Attorneys for Plaintiff NETLIST, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA OAKLAND DIVISION NETLIST, INC., Plaintiff, v. GOOGLE INC., Defendant. CASE NO. CV-09-05718 SBA [Related to Case No. CV-08-04144 SBA] DECLARATION OF STEVEN R. HANSEN IN SUPPORT OF PLAINTIFF NETLIST, INC.'S OPENING CLAIM CONSTRUCTION BRIEF DECLARATION OF STEVEN R. HANSEN IN SUPPORT OF CLAIM CONSTRUCTION BRIEF (CASE NO. C-09-05718 SBA) 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 DECLARATION OF STEVEN R. HANSEN I, Steven R. Hansen, declare as follows: 1. I am an attorney admitted to practice in the states of California and Michigan and before this Court. I am of counsel to Lee Tran & Liang APLC, counsel of record for Plaintiff Netlist, Inc. ("Netlist"). I have personal knowledge of the facts set forth herein and, if called as a witness, could and would testify competently thereto under oath. This declaration is made in support of Netlist's Opening Claim Construction Brief. 2. A true and correct copy of Netlist's U.S. Patent No. 7,619,912 (the "'912 Patent") is attached hereto as Exhibit "A". 3. The JEDEC Dictionary of Terms for Solid State Technology defines a "bank address" as follows: "In a RAM that has multiple banks in its architecture, the address used to select any one of the available banks." A true and correct copy of the relevant pages of the JEDEC Dictionary of Terms for Solid State Technology is attached hereto as Exhibit "B". 4. On or about May 18, 2010 I took the deposition of Google's technical expert, William Hoffman, in the related Case No. CV-08-04144 SBA. A true and correct copy of relevant excerpts of the transcript of Mr. Hoffman's May 18, 2010 deposition are attached hereto as Exhibit "C". Although originally designated as confidential, Google has stipulated to "dedesignate" the partitions of Mr. Hoffman's transcripts included in Exhibit "C". 5. A true and correct copy of relevant portions of The Authoritative Dictionary of IEEE Standards Terms, Seventh Ed. 2000 is attached hereto as Exhibit "D". 6. A true and correct copy of page 1193 of the New Oxford American Dictionary (2d.ed. 2005) is attached hereto as Exhibit "E". 7. A true and correct copy of 2173.05(g) of the Manual of Patent Examining Procedure (8th ed., Rev. July 2008) is attached hereto as Exhibit "F". 8. On or about May 14, 2010, Google served its Invalidity Contentions on counsel for Netlist. A true and correct copy of Google's Invalidity Contentions and exhibits 6 and 14 thereto are attached hereto as Exhibit "G". 2 DECLARATION OF STEVEN R. HANSEN IN SUPPORT OF CLAIM CONSTRUCTION BRIEF (CASE NO. C-09-05718 SBA) 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 declare under penalty of perjury under the laws of the United States and the State of California that the foregoing is true and correct. Executed this 16th day of July 2010, at Waterford, Michigan ___________/s/ Steven R. Hansen_____________________________ Steven R. Hansen 3 DECLARATION OF STEVEN R. HANSEN IN SUPPORT OF CLAIM CONSTRUCTION BRIEF (CASE NO. C-09-05718 SBA)

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