Louis Vuitton Malletier, S.A. v. Akanoc Solutions, Inc. et al

Filing 149

Declaration of James A. Lowe in Support of 148 MOTION Require Plaintiff to "Pare Down" its Infringement Contentions for Trial filed byAkanoc Solutions, Inc., Managed Solutions Group, Inc., Steven Chen. (Attachments: # 1 Exhibit 1541 to Lowe Decl, # 2 Exhibit 1542 to Lowe Decl)(Related document(s) 148 ) (Lowe, James) (Filed on 5/11/2009)

Louis Vuitton Malletier, S.A. v. Akanoc Solutions, Inc. et al

Doc. 149

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GAUNTLETT & ASSOCIATES David A. Gauntlett (SBN 96399) James A. Lowe (SBN 214383) Brian S. Edwards (SBN 166258) Christopher Lai (SBN 249425) 18400 Von Karman, Suite 300 Irvine, California 92612 Telephone: [phone] Facsimile: [phone] [e-mail] [e-mail] [e-mail] Attorneys for Defendants Akanoc Solutions, Inc., Managed Solutions Group, Inc. and Steve Chen

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA, SAN JOSE DIVISION

LOUIS VUITTON MALLETIER, S.A., Plaintiff, vs. AKANOC SOLUTIONS, INC., et al., Defendants.

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Case No.: C 07-3952 JW (HRL) DECLARATION OF JAMES A. LOWE IN SUPPORT OF DEFENDANTS' MOTION TO REQUIRE PLAINTIFF LOUIS VUITTON TO "PARE DOWN" ITS INFRINGEMENT CONTENTIONS FOR TRIAL Date: June 15, 2009 Time: 9:00 a.m. Ctrm.: 8, 4th Floor

164966.1-10562-002-5/11/2009

DECL. OF JAMES A. LOWE IN SUPPORT OF DEFENDANTS' MOTION TO REQUIRE VUITTON TO "PARE DOWN" INRINGEMENT CONTENTIONS FOR TRIAL ­ C 07-3952 JW (HRL)

Dockets.Justia.com

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I, JAMES A. LOWE, declare: 1. I am an attorney duly licensed to practice law before this Court and am a partner in

the law firm of Gauntlett & Associates, counsel of record for defendants Managed Solutions Group, Inc., Akanoc Solutions, Inc. and Steve Chen ("Defendants"). 2. I have personal knowledge of the facts stated in this Declaration and could testify

competently to them if called upon as a witness. 3. This Declaration is submitted in support of Defendants' Motion to Require Plaintiff

Louis Vuitton ("Vuitton") to "Pare Down" its Infringement Contentions for Trial. 4. Attached as Exhibit "1541" is a 1 page sample verdict form prepared by my office.

It covers a single contributory copyright infringement claim (alleged infringement of Vuitton's "Multicolor Monogram-White Print" copyrighted work) by a single defendant (Managed Solutions Group, Inc.) at one accused website (Ape168.com). 5. Attached as Exhibit "1542" is a 1.5 page sample verdict form also prepared by my

This verdict form covers a single contributory trademark infringement claim (alleged

infringement of the "Louis Vuitton (Interlocked Letters) Design" trademark) by a single defendant (Managed Solutions Group, Inc.) at one accused website (Ape168.com). 6. These sample verdict forms represent the minimum findings a jury needs to make as

to each alleged infringement of a Vuitton mark or copyrighted work, by each defendant, at each accused website. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed at Irvine, California on May 11, 2009.

s/ James A. Lowe James A. Lowe

164966.1-10562-002-5/11/2009

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DECL. OF JAMES A. LOWE IN SUPPORT OF DEFENDANTS' MOTION TO REQUIRE VUITTON TO "PARE DOWN" INRINGEMENT CONTENTIONS FOR TRIAL ­ C 07-3952 JW (HRL)