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

Filing 192

Declaration of James A. Lowe in Support of DEFENDANTS' OBJECTIONS TO LANGUAGE OF VUITTON'S PROPOSED PERMANENT INJUNCTION filed by Akanoc Solutions, Inc., Steven Chen, Managed Solutions Group, Inc.. (Attachments: # 1 Group Exhibit 1600 to Lowe Declaration)(Related document(s) 191 ) (Lowe, James) (Filed on 8/7/2009) Modified on 8/14/2009 (cv, COURT STAFF).

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

Doc. 192

Case5:07-cv-03952-JW Document192

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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' OBJECTIONS TO LANGUAGE OF VUITTON'S PROPOSED PERMANENT INJUNCTION

165740.1-10562-002-8/7/2009

DECL. OF JAMES A. LOWE IN SUPPORT OF DEFENDANTS' OBJECTIONS TO LANGUAGE OF PROPOSED PERMANENT INJUNCTION ­ C 07-3952 JW (HRL)

Dockets.Justia.com

Case5:07-cv-03952-JW Document192

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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' objections to the language of

plaintiff Louis Vuitton Malletier, S.A.'s ("Vuitton") proposed permanent injunction. 4. Attached as Exhibit "1600.1" are excerpts from a Quarterly Revenue Report issued

in 2006 by Vuitton's parent company, LVMH and reporting sales results for Louis Vuitton. 5. Attached as Exhibit "1600.2" are excerpts from a Quarterly Revenue Report issued

in 2007 by Vuitton's parent company, LVMH and reporting sales results for Louis Vuitton. 6. Attached as Exhibit "1600.3" are excerpts from a Quarterly Revenue Report issued

in 2007 by Vuitton's parent company, LVMH and reporting sales results for Louis Vuitton. 7. Attached as Exhibit "1600.4" are excerpts from a Quarterly Revenue Report issued

in 2008 by Vuitton's parent company, LVMH and reporting sales results for Louis Vuitton. 8. Attached as Exhibit "1600.5" are excerpts from a Quarterly Revenue Report issued

in 2008 by Vuitton's parent company, LVMH and reporting sales results for Louis Vuitton. 9. Attached as Exhibit "1600.6" are excerpts from a Quarterly Revenue Report issued

in 2009 by Vuitton's parent company, LVMH and reporting sales results for Louis Vuitton. 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 August 7, 2009.

s/ James A. Lowe James A. Lowe

165740.1-10562-002-8/7/2009

DECL. OF JAMES A. LOWE IN SUPPORT OF DEFENDANTS' OBJECTIONS TO LANGUAGE OF PROPOSED PERMANENT INJUNCTION ­ C 07-3952 JW (HRL)