Google Inc. v. American Blind & Wallpaper Factory, Inc.

Filing 139

Declaration of Klaus H. Hamm in Support of Google Inc.'s Opposition to American Blind & Wallpaper Factory, Inc.'s Motion to Compel filed byGoogle Inc., Google Inc.. (Attachments: # 1 Exhibit A-E)(Hamm, Klaus) (Filed on 7/12/2006)

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Google Inc. v. American Blind & Wallpaper Factory, Inc. Doc. 139 Case 5:03-cv-05340-JF Document 139 Filed 07/12/2006 Page 1 of 2 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 MICHAEL H. PAGE - #154913 MARK A. LEMLEY - #155830 KLAUS H. HAMM - #224905 710 Sansome Street San Francisco, CA 94111-1704 Telephone: (415) 391-5400 Facsimile: (415) 397-7188 Attorneys for Plaintiff and Counter Defendant GOOGLE INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA GOOGLE INC., a Delaware corporation, Plaintiff, v. AMERICAN BLIND & WALLPAPER FACTORY, INC., a Delaware corporation d/b/a decoratetoday.com, Inc., and DOES 1100, inclusive, Defendants. AMERICAN BLIND & WALLPAPER FACTORY, INC., a Delaware corporation d/b/a decoratetoday.com, Inc., Counter Plaintiff, v. GOOGLE INC., AMERICA ONLINE, INC., NETSCAPE COMMUNICATIONS CORPORATION, COMPUSERVE INTERACTIVE SERVICES, INC., ASK JEEVES, INC. and EARTHLINK, INC., Counter Defendant/ Third-Party Defendants. Case No. C 03-5340-JF (RS) DECLARATION OF KLAUS H. HAMM IN SUPPORT OF GOOGLE INC.'S OPPOSITION TO AMERICAN BLIND & WALLPAPER FACTORY, INC.'S MOTION TO COMPEL AND FOR SANCTIONS PURSUANT TO F.R.C.P. 37(a) Date: Time: Dept: Judge: August 9, 2006 9:30 a.m. 4 Honorable Richard Seeborg November 26, 2003 Date Comp. Filed: Trial Date: May 15, 2007 REDACTED VERSION 376893.01 DECLARATION OF KLAUS H. HAMM IN SUPPORT OF GOOGLE INC.'S OPPOSITION TO AMERICAN BLIND & WALLPAPER FACTORY, INC.'S MOTION TO COMPEL AND FOR SANCTIONS PURSUANT TO F.R.C.P. 37(a) CASE NO. C 03-5340-JF (RS) Dockets.Justia.com Case 5:03-cv-05340-JF Document 139 Filed 07/12/2006 Page 2 of 2 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, Klaus H. Hamm, declare as follows: 1. I am associated with the firm of Keker & Van Nest LLP, counsel for Plaintiff Google Inc., and am admitted to practice before this Court. Unless otherwise specified, the facts set forth herein are known to me of my personal knowledge, and if called upon I can testify truthfully thereto. List of Attached Exhibits 2. Attached hereto as Exhibit A is a true and correct copy of a letter and attachments from myself to counsel for American Blind & Wallpaper Factory, Inc. ("American Blind"), Dawn M. Beery, on October 27, 2005. Google has under separate cover requested that this document be filed under seal. 3. Attached hereto as Exhibit B is a true and correct copy of a letter from myself to counsel for American Blind, David A. Rammelt, on April 6, 2006. 4. Attached hereto as Exhibit C is a true and correct copy of a document Bates numbered GGLE0020950 GGLE0021227, and produced by Google to American Blind on April 6, 2006. Google has under separate cover requested that this document be filed under seal. 5. Attached hereto as Exhibit D is a true and correct copy of a document Bates labeled GGL002818 GGL002820, and is Exhibit No. 6 to the Deposition of Alana Karen, taken on April 12, 2006. Google has under separate cover requested that this document be filed under seal. 6. Attached hereto as Exhibit E is a true and correct copy of email correspondence from May 2, 2006 between my colleague Michael Page, and Mr. Rammelt and Susan Greenspan who are counsel for American Blind. I state under penalty of perjury of the laws of the United States of America that the foregoing statements are true and correct and that this declaration was executed on July 12, 2006. /s/ Klaus H. Hamm KLAUS H. HAMM 1 DECLARATION OF KLAUS H. HAMM IN SUPPORT OF GOOGLE INC.'S OPPOSITION TO AMERICAN BLIND & WALLPAPER FACTORY, INC.'S MOTION TO COMPEL AND FOR SANCTIONS PURSUANT TO F.R.C.P. 37(a) CASE NO. C 03-5340-JF (RS) 376893.01

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