Mou v. City of San Jose et al

Filing 430

Mou v. City of San Jose et al

Doc. 430 Att. 9

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JEFFREY L. BLEICH (SBN 144340) ROHIT K. SINGLA (SBN 213057) VICTORIA L. BOESCH (SBN 228561) MUNGER, TOLLES & OLSON LLP 560 Mission Street Twenty-Seventh Floor San Francisco, CA 94105-2907 Telephone: [phone] Facsimile: [phone] E-Mail: [e-mail]; [e-mail]; [e-mail] Attorneys for Plaintiff APPLIED MATERIALS, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION APPLIED MATERIALS, INC., Plaintiff, vs. MULTI METRIXS, LLC, Defendant. CASE NO. C-06-7372 MHP DECLARATION OF ROHIT K. SINGLA IN SUPPORT OF PLAINTIFF APPLIED MATERIALS, INC.'S MOTION FOR ATTORNEY FEES NOTICE OF MOTION AND MOTION FOR ATTORNEY FEES AND PROPOSED ORDER FILED CONCURRENTLY Judge: Date: Time: Courtroom: Hon. Marilyn H. Patel January 26, 2009 2:00 p.m. 15, 18th Floor

[EXHIBITS A & C FILED UNDER SEAL]

I, Rohit K. Singla, declare: 1. I am an attorney duly licensed to practice in the State of California and in the

United States District Court for the Northern District of California. I am a partner in the firm of Munger, Tolles & Olson LLP ("Munger Tolles"), counsel of record for Plaintiff Applied Materials, Inc. ("Applied") in this litigation. I was one of the lawyers at the firm with principal responsibility for the trial and pre-trial proceedings in this litigation. This declaration is made in
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support of Applied's Motion for Attorney Fees. The following facts are within my personal knowledge based upon my representation of Applied in this litigation. I would be competent to testify to the facts stated herein if called to do so. 2. Attached as Exhibit A to this declaration is a true and correct copy of an excerpt

from the transcript of the deposition of Boris Kesil taken on September 6, 2007. 3. Attached as Exhibit B to this declaration is a true and correct copy of Defendant

MultiMetrixs' Second Supplemental Objections and Responses to Applied's First Set of Interrogatories. 4. Attached as Exhibit C to this declaration is a true and correct copy of an excerpt of

the report submitted by A. J. Nichols, the Special Master appointed by the Court to retrieve documents from MultiMetrixs. 5. I personally reviewed the Special Master's index of files and observed that, at least

based on the names of the files in the index, it appeared the Special Master had found hundreds of responsive and relevant documents on Elik Gershenzon's personal computer that had not been produced in discovery in this litigation. 6. Munger Tolles has performed legal services in the above-captioned matter and

these services were billed to Applied and paid by Applied. Services were provided by firm attorneys including myself, Jeffrey L. Bleich, Peter A. Detre, Martin D. Bern, Daniel Beck, Erin C. Dougherty and Victoria L. Boesch. (Mr. Beck and Ms. Dougherty are no longer with the firm.) Additional services were performed by a legal assistant, Bonnie M. Follett, who worked under the direction of attorneys. Litigation Support Specialist Shannon Bales also worked on the matter under the direction of firm attorneys. 7. The legal services provided to Applied were billed on an hourly basis using the

firm's customary hourly rates for the services provided. Hourly rates were generally increased for all clients in Jan. 2007 and Jan. 2008. Records of the time billed to Applied were kept in the firm's customary manner, through its electronic timekeeping and accounting systems. 8. The hourly rates charged to Applied for the services of individuals mentioned in

Paragraph 6 above are as follows:
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1

Name Jeffrey L. Bleich (partner) Peter A. Detre (partner) Rohit K. Singla (partner) Martin D. Bern (partner) Daniel Beck (associate) Erin C. Dougherty (associate) Victoria L. Boesch (associate) Bonnie M. Follett (paralegal) Shannon Bales (litig. support)

2006 $575 $460

2007 $600 $500 $470 $425 $275 $195

2008 $650 $525 $550 $350 $420 $200 $295

$395

9. 10.

These rates were actually paid by Applied in connection with this matter. Based upon my experience, including experience litigating fee issues in cases in

this district, the rates charged by Munger Tolles, including the rates charged in this case, are lower than the majority of our peer firms with lawyers of similar experience and credentials. 11. Attached as Exhibit D to this declaration is a true and correct copy of an excerpt of

the American Intellectual Property Law Association's 2007 Report of the Economic Survey showing the following average hourly billing rates for private firm intellectual property lawyers working in San Francisco in 2006: Partners $469, Associates $337.1 As the AIPLA data includes patent prosecutors, who typically bill at a lower rate than litigators, these 2006 figures strongly support the reasonableness of the rates billed by Munger Tolles in this matter. 12. Attached as Exhibit E to this declaration is a true and correct copy of a chart

submitted by Morrison & Foerster in connection with a motion for attorney fees in another patent case with which I am involved (Abbott v. Roche Diagnostics Corp. et al., Case No. C 05 3117 JF, United States District Court for the Northern District of California). Below is a comparison between the Morrison & Foerster hourly billing rates and Munger Tolles' rates in this case. Again, the data supports the reasonableness of Munger Tolles' rates.

The Federal Circuit has held that the AIPLA report may be used to determine reasonable rates for patent litigation. See, e.g., View Eng'g, Inc. v. Robotic Vision Sys., Inc., 208 F.3d 981, 98788 (Fed. Cir. 2000) (affirming a fee request reduction based on a difference between the submitted fees and the fees stated in the AIPLA survey); Mathis v. Spears, 857 F.2d 749, 755-56 (Fed. Cir. 1988) (affirming a fee request because the rates corresponded to those stated in the AIPLA survey). -3SINGLA DECLARATION ISO APPLIED'S ATTORNEY FEE MOTION CASE NO:iC-06-7372 MHP Exh bit 10

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Timekeeper Category Partners: M&F MTO Associates: M&F MTO Paralegals: M&F MTO Lit. Support: M&F MTO

2006 $460-$700 $460-$575 $235-$470 $395 $125-$195 ญญญญญญ $200 ญญญญญญ

2007 $545-$750 $470-$600 $270-$530 $275-$425 $135-$205 $195 $225 ญญญญญญ

2008 $546-$745 $525-$650 $332-$532 $350-$420 $128-$242 $200 $228 $295

13.

Jeffrey L. Bleich is a litigation partner in Munger Tolles' San Francisco office. He

received his J.D. from Berkeley Law (Boalt Hall) and served as a law clerk to Judge Abner J. Mikva, U.S. Court of Appeals for the D.C. Circuit; Chief Justice William H. Rehnquist, U.S. Supreme Court and Judge Howard Holzmann, Iran-U.S. Claims Tribunal at The Hague. Mr. Bleich also served as the 2007-2008 President of the State Bar of California. In connection with this litigation, Mr. Bleich participated in all aspects of trial preparation beginning in October 2006 and participated in the trial. From the inception of the litigation until the Court issued its ruling on Inequitable Conduct, Mr. Bleich worked 391.30 hours on the litigation (167.8 hours on pretrial proceedings and discovery, 110.90 hours on trial preparation, 48.70 hours during trial, and 63.90 hours on post-trial proceedings) that were billed to and paid for by Applied. 14. Peter A. Detre is a litigation partner in Munger Tolles' San Francisco office. He

received his J.D. from Yale School of Law and served as a law clerk to Judge Kimba M. Wood, U.S. District Court for the Southern District of New York. In connection with this litigation, Mr. Detre worked on pre-trial proceedings (including drafting pleadings, conducting research and overseeing discovery) from October 2006 until September 2007. During this timeframe, Mr. Detre worked 169.40 hours on pre-trial proceedings and discovery in the litigation that were billed to and paid for by Applied. 15. I (Rohit K. Singla) am a litigation partner in Munger Tolles' San Francisco office.

I received my J.D. from Harvard School of Law and served as a law clerk to Judge Alfred T. Goodwin, U.S. Court of Appeals for the Ninth Circuit. Beginning in late June 2007, I participated in all aspects of pre-trial proceedings and discovery, trial preparation, trial and postSINGLA DECLARATION ISO APPLIED'S ATTORNEY FEE MOTION CASE NO:iC-06-7372 MHP Exh bit 10

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trial proceedings. From June 2007 until the Court issued its ruling on Inequitable Conduct, I worked 781.70 hours on the litigation (260.50 hours on pre-trial proceedings and discovery, 268.0 hours on trial preparation, 60.20 hours during trial, and 194.0 hours on post-trial proceedings) that were billed to and paid for by Applied. 16. Martin D. Bern is a litigation partner in Munger Tolles' San Francisco office. He

received his J.D. from Berkeley Law (Boalt Hall) and served as a law clerk to Judge J. Gifford Wallace, U.S. Court of Appeals for the Ninth Circuit and to Judge Charles A. Legge, U.S. District Court for the Northern District of California. In February and March of 2008, Mr. Bern stepped in to assist with the trial preparation for this case, including drafting outlines for direct and cross examinations. Mr. Bern worked 66.50 hours on trial preparation that were billed to and paid for by Applied. 17. Daniel Beck was formerly an associate in Munger Tolles' Los Angeles office. He

received his J.D. from Yale School of Law. From October 2006 through August 2007, Mr. Beck worked on trial preparation for this case including witness interviews, document production, legal research and drafting discovery and discovery responses. During this timeframe, Mr. Beck worked 202.10 hours on pre-trial proceedings and discovery for the litigation that were billed to and paid for by Applied. 18. Erin Dougherty was formerly an associate in Munger Tolles' San Francisco office.

She received her J.D. from Columbia University School of Law and served as a law clerk to Judge Sidney R. Thomas, U.S. Court of Appeals for the Ninth Circuit. From March 2007 through March 2008, Ms. Dougherty participated in trial preparation for this case (including drafting pleadings, taking and defending depositions and responding to discovery). She also participated in the trial itself, including the examination of a witness at trial. During the year she worked on the case, Ms. Dougherty spent 791.10 hours on the litigation (360.90 hours on pre-trial proceedings and discovery, 374.0 hours on trial preparation, 50.50 hours during trial, and 5.70 hours on post-trial proceedings) that were billed to and paid for by Applied. 19. Victoria L. Boesch is an associate in Munger Tolles San Francisco office. She

received her J.D. from Berkeley Law (Boalt Hall) and served as a law clerk to Judge A. Wallace
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Tashima, U.S. Court of Appeals for the Ninth Circuit. Beginning in late February 2008, Ms. Boesch worked on trial preparation and post-trial briefing for this case. From February 2008 until the Court issued its ruling on Inequitable Conduct, Ms. Boesch worked 297.00 hours on the litigation (53.7 hours on trial preparation and 243.3 hours on post-trial proceedings) that were billed to and paid for by Applied. 20. Bonnie Follett is a paralegal in Munger Tolles' San Francisco office. Beginning in

April 2007, Ms. Follett performed work on this case involving document organization and management in connection with document production, the receipt of documents in discovery and trial preparation. From April 2007 until the Court issued its ruling on Inequitable Conduct, Ms. Follett worked 486.50 hours on the litigation (175.50 hours on pre-trial proceedings and discovery, 157.80 hours on trial preparation, 35.40 hours during trial, and 117.80 hours on posttrial proceedings) that were billed to and paid for by Applied. 21. Shannon Bales is an Automated Litigation Specialist in Munger Tolles' Los

Angeles office who specializes in trial support. Beginning in late February 2008, Mr. Bales provided technical support for the trial team in connection with trial presentations and post-trial proceedings. From February 2008 through April 2008, Mr. Bales worked 202.20 hours on the litigation 110.50 hours on trial preparation, 58.50 hours during trial, and 33.20 hours on post-trial proceedings) that were billed to and paid for by Applied. 22. From the inception of the litigation until the Court issued its ruling on Inequitable

Conduct, Munger Tolles incurred $52,932.44 in costs on behalf of Applied in connection with this matter. These costs included copying and telephone charges, travel expenses, research expenses, filing and service fees, meals, deposition expenses, translation services and transcripts. The costs were billed to and paid by Applied. 23. follows: /// /// ///
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The fees and costs previously discussed in this declaration can be summarized as

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Name Jeffrey L. Bleich Peter A. Detre Rohit K. Singla Martin D. Bern Daniel Beck Erin C. Dougherty Victoria L. Boesch Bonnie M. Follett Shannon Bales Costs Total

Hours 391.30 169.40 781.70 66.50 202.10 791.10 297.00 486.50 202.20

Amount Paid $245,605.00 $82,612.00 $396,120.00 $36,575.00 $83,453.50 $249,817.50 $124,740.00 $96,422.50 $59,649.00 $52,932.44 $1,427,926.94

24.

The above-described work was performed (and the above-described costs were

incurred) solely for the purpose of pursuing this matter on behalf of Applied. 25. The services performed and the attorney's fees and expenses detailed in this

declaration were all reasonably necessary to represent the interests of Applied in this lawsuit. Applied had a reasonable expectation that if it prevailed in this matter, its fees and expenses to pursue this dispute with defendant would be recoverable as provided by statute. 26. I did not meet and confer with counsel for MultiMetrixs regarding the motion that

accompanies this declaration because it is my understanding that MultiMetrixs currently does not have counsel representing it in connection with this litigation.

I declare under the penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed this 3rd day of December 2008, at San Francisco, California. _______ /s/ Rohit K. Singla Rohit K. Singla

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Exhibit D

60

Exhibit 10

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AIPLA
Report of the Economic Survey 2007
P r e p a r e d Under Direction of Law Practice Management Committee
American Intellectual Property Law Association
241 18th Street South, Suite 700 Arlington, Virginia 22202 www.ai1 la.org 6p
Exhibit 10

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AIPLA
REPORT OF THE ECONOMIC SURVEY 2007
PREPARED UNDER DIRECTION OF THE AMERICAN INTELLECTUAL PROPERTY LAW ASSOCIATION LAW PRACTICE MANAGEMENT COMMITTEE KEVIN ALAN WOLFF, CHAIR ASHOK K. MANNAVA, VICE CHAIR
July 2007

4 RESEARCH PLACE, SUITE 220 ROCKVILLE, MARYLAND 20850 TEL: [phone] [e-mail]

62

Exhibit 10

CaseCase3:06-cv-07372-MHP Private Firm, Partner 2:08-cv-08439-R-RC Document 218-13 Document122-1 Filed12/03/08 Page29 of 29 of 32 Filed 06/22/2009 Page 32
Average hourly billing rate in 2006 (Q29) Private Firm, Partner What was your average hourly billing rate in 2006? First T h i rd Quartile Quartile Number of Mean Median 25% 75% Individuals (Average) (Midpoint) 827 $390 $300 $380 $475 6 $192 $144 $200 $231 30 $281 $239 $250 $311 120 $327 $260 $308 $400 226 $371 $295 $370 $450 237 $407 $313 $400 $495 142 $446 $340 $430 $529 58 $458 $369 $460 $546 46 $512 $436 $503 $575 50 $453 $390 $443 $541 26 $405 $344 $400 $429 125 $435 $360 $430 $505 41 $306 $250 $300 $345 35 $381 $325 $375 $435 16 $279 $206 $290 $348 64 $398 $326 $380 $450 38 $367 $300 $375 $429 147 $298 $250 $295 $330 62 $407 $340 $400 $486 37 $461 $330 $485 $553 49 $469 $393 $460 $530 80 $344 $271 $330 $403 61 $413 $315 $425 $490 102 $375 $299 $370 $440 15 $422 $350 $400 $545 57 $395 $310 $400 $483 79 $405 $315 $400 $475 177 $337 $275 $315 $398 9 $446 $320 $425 $588 17 $287 $225 $275 $323 119 $338 $250 $320 $420 191 $367 $280 $350 $440 166 $382 $295 $379 $450 120 $416 $340 $400 $494 97 $437 $328 $425 $508 110 $444 $338 $448 $541 726 $392 $300 $380 $475 94 $368 $284 $365 $450 538 $388 $295 $375 $475 187 $398 $305 $395 $490 54 $378 $300 $383 $466 744 $392 $300 $385 $479 7 $350 $225 $330 $500 29 $353 $250 $330 $453 3 $243 NA $240 NA 16 $348 $300 $328 $401 59 $278 $225 $255 $325 95 $318 $250 $315 $375 81 $322 $258 $315 $355 174 $343 $275 $330 $400 115 $409 $325 $400 $490 158 $453 $380 $450 $511 50 $502 $429 $493 $571 84 $507 $435 $500 $579

All Individuals Fewer than 5 5-6 7-9 10-14 15-24 25-34 35 or More Boston CMSA NYC CMSA Philadelphia CMSA W ashington, DC CMSA Other East Metro Southeast Other Southeast Chicago CMSA Minne.-St. Paul PMSA Other Central Texas Los Angeles CMSA San Francisco CMSA Other West Biotechnology Chemical Computer Hardware Computer Software Electrical Mechanical Other areas Younger than 35 35-39 40-44 45-49 50-54 55-59 60 or Older Male Female Bachelor's Degree Master's Degree Doctorate Degree W hite/Caucasian Hispanic/Latino Asian/Pacific Islander Blended Other 1-2 3-5 6-10 11-25 26-50 51-100 101-150 More than 150

Years of Intellectual Property Law Experience

Location

IP Technical Specialization (>=50%)

Age

Gender Highest Non-Law Degree

Ethnicity

Full-time Intellectual Property lawyers and agents in the firm or corporation

AIPLA Report of the 63 Economic Survey 2007 I-30

Exhibit 10

CaseCase3:06-cv-07372-MHP PDocument122-1 Filed12/03/08 Page30 of 30 of 32 2:08-cv-08439-R-RC Document 218-13 Filed rivate Firm, Associate 06/22/2009 Page 32
Average hourly billing rate in 2006 (Q29) Private Firm, Associate What was your average hourly billing rate in 2006? First Third Quartile Quartile Number of Mean Median 25% 75% Individuals (Average) (Midpoint) 481 $262 $200 $245 $315 269 $226 $180 $210 $260 99 $303 $240 $300 $355 71 $326 $260 $315 $395 21 $340 $268 $300 $413 5 $324 $218 $285 $450 25 $310 $235 $320 $353 27 $341 $260 $330 $425 12 $242 $216 $245 $289 80 $297 $240 $300 $348 23 $216 $160 $208 $260 14 $246 $218 $228 $291 6 $248 $203 $243 $293 28 $250 $221 $245 $279 28 $207 $175 $195 $233 85 $210 $165 $190 $248 33 $288 $235 $295 $335 18 $300 $254 $298 $328 24 $337 $258 $318 $413 72 $240 $180 $210 $269 55 $281 $220 $275 $330 68 $273 $200 $260 $350 11 $320 $230 $300 $425 40 $270 $216 $250 $324 62 $264 $210 $250 $303 90 $239 $180 $215 $293 10 $311 $200 $345 $371 219 $238 $180 $225 $285 127 $277 $215 $265 $335 77 $289 $228 $270 $335 35 $317 $225 $310 $410 11 $249 $175 $235 $300 8 $202 $176 $185 $185 3 $288 NA $325 NA 368 $266 $200 $250 $315 110 $249 $185 $225 $313 268 $254 $185 $235 $300 119 $266 $215 $255 $315 72 $281 $210 $262 $340 412 $257 $200 $240 $309 5 $258 $183 $235 $345 9 $311 $263 $315 $328 31 $279 $210 $260 $325 4 $393 NA $408 NA 7 $304 $245 $285 $325 15 $229 $175 $200 $270 35 $196 $170 $195 $210 42 $225 $175 $225 $276 98 $230 $180 $215 $261 97 $266 $210 $260 $305 87 $291 $225 $290 $350 34 $310 $240 $298 $371 57 $319 $250 $320 $380

All Individuals Years of Intellectual Property Law Experience Fewer than 5 5-6 7-9 10-14 15-24 Boston CMSA NYC CMSA Philadelphia CMSA Washington, DC CMSA Other East Metro Southeast Other Southeast Chicago CMSA Minne.-St. Paul PMSA Other Central Texas Los Angeles CMSA San Francisco CMSA Other West Biotechnology Chemical Computer Hardware Computer Software Electrical Mechanical Other areas Younger than 35 35-39 40-44 45-49 50-54 55-59 60 or Older Male Female Bachelor's Degree Master's Degree Doctorate Degree White/Caucasian Black/African American Hispanic/Latino Asian/Pacific Islander Blended Other 1-2 3-5 6-10 11-25 26-50 51-100 101-150 More than 150

Location

IP Technical Specialization (>=50%)

Age

Gender Highest Non-Law Degree

Ethnicity

Full-time Intellectual Property lawyers and agents in the firm or corporation

AIPLA Report of the 64 Economic Survey 2007 I-44

Exhibit 10

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Exhibit E

65

Exhibit 10

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Abbott v. Roche Bayer #59958-1 Time Recap Report by Timekeeper and Year 2005 Billed Hours 0 82 206.75 288.75 2006 Billed Hours 1326.75 322.5 632.5 2,281.75 2008 Rate (w/ 5% discount) $546.25 $745.75 $665.00

Tk No.

Description

Title Partner Partner Partner

2005 Rate $425 $650 $565

2005 Fees Billed $ $ $ $ 53,300 116,814 170,114

2006 Rate $460 $700 $600

2006 Fees Billed

2007 2007 Billed Rate Hours 1937.75 652 1677.25 4,267.00 $ $ $ $

2007 Fees Billed 1,048,321 486,638 1,119,724 2,654,682

2008 Std Rate $575 $785 $700

2008 Billed Hours (thru 9/18/08) 2008 Fees Billed 1,121 634 1,002.25 2,757.25 $ $ $ $ 609,234 469,615 662,941 1,741,790

Total Hours 4,385.50 1,690.50 3,518.75 9,594.75 $ $ $ $

Total Value 2,271,883 1,235,302 2,278,978 5,786,163

7269 Barlett, Jason R. 295 Krevans, Rachel 3960 Overson, Wesley Subtotal - Partners

$ 614,328 $545 $ 225,750 $750 $ 379,500 $675 $ 1,219,578

10296 Guerra, Marcelo O. 10260 Ho, Brian 8691 Jorjani, Parisa 11563 Pikler, Jason A. 11555 Edgar, Jared D. 10245 Hartwig, Johanna K. 7299 Pugh, Louis H. 10258 Cary-Sadler, Tel B. 99784 Lobo, Bethany 8932 Klestoff, Alexei Subtotal - Associates

Associate Associate Associate Associate Associate Associate Associate Associate Associate Associate

$225 $225 $395 $195 $195 $225 $435 $225 $295

210.5 372.25 0 0 0 67 554 0 0 0 1,203.75

$ $ $ $ $ $ $ $ $ $ $

47,363 83,756 15,075 240,990 387,184

$285 $285 $440 $235 $235 $285 $470 $285 $360

1,322.75 1,411.25 0 0 258 760.25 237 317 0 0 4,306.25

$ 375,701 $ 402,206 $ $ $ 60,630 $ 216,671 $ 111,390 $ 90,345 $ $ $ 1,256,944

$375 $360 $530 $270 $270 $375 $375 $270 $460

1940.5 1168.25 1569.5 1377 1077.25 487 0 268.25 0 0 7,887.75

$ $ $ $ $ $ $ $ $ $ $

714,441 416,043 818,810 367,585 285,674 179,878 100,369 2,882,799

$445 $430 $560 $350 $445 $350 $520

$422.75 $408.50 $532.00 $332.50 $422.75 $332.50 $494.00

947.5 384.75 822.25 794.50 0 0 0 0 524.75 425 3,898.75

$ $ $ $ $ $ $ $ $ $ $

398,626 155,750 434,854 262,726 173,281 208,034 1,633,271

4,421.25 3,336.50 2,391.75 2,171.50 1,335.25 1,314.25 791.00 585.25 524.75 425.00 17,296.50

$ $ $ $ $ $ $ $ $ $ $

1,536,130 1,057,756 1,253,664 630,311 346,304 411,624 352,380 190,714 173,281 208,034 6,160,198

7160 Meier, Christopher M. 11785 Bhaumik, Nishan 7471 Pooni, Vikashni S. 13495 Kintzer, Geoffrey 13971 Nowakowski, Monika M. 12629 Adam, Rachel W. 11820 Menchaca, Katherine M. Subtotal - Paralegals 12206 12831 12227 12494 12859 4735 11055 12465 Rnjak, Bojana A. Hom, Richard Liao, Kevin Mercer, Michael D. Silverman, Robert N. Wu, Frank Rao, Swathi K. Hajos, Brigitte A.

Snr Paralegal Paralegal Paralegal Paralegal Paralegal Paralegal Paralegal

$185 $160 $120

0 0 0 0 0 0 0 0 0 0 0 0 0 0 25 0 25

$ $ $ $ $ $ $ $ $ $ $ $$ $ $ $ $

4,625 4,625

$195 $130 $170 $125 $130

0 0 241.75 0 0 0 0 241.75 1,500.25 381.25 487.5 0 0 239.25 131.5 0 2,739.75

$ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $

41,098 41,098 262,544 62,906 85,313 $83,738 26,300 520,800

$205 $135 $180 $160 $135 $145

325 843.75 1,132.75 515.5 0 467.25 0 3,284.25 1,208.75 2,167.25 0 56.5 256.25 0 0 95.25 3,784.00

$ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $

66,625 113,906 202,059 82,480 61,833 526,904 211,570 370,934 $11,813 57,656 29,374 681,347

$255 $185 $205 $175 $190 $135 $190

$242.25 $175.75 $194.75 $166.25 $180.50 $128.25 $180.50

937 708 0 727 695 0 336.75 3,403.75 0 39.25 0 155 28 0 0 0 222

$ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $

225,704 123,695 120,117 124,698 60,253 654,467 7,219 $34,925 6,312 48,457

1,262.00 1,551.75 1,374.50 1,242.50 695.00 467.25 336.75 6,929.75 2,709.00 2,587.75 487.50 211.25 284.25 239.25 156.50 95.25 6,770.75

$ $ $ $ $ $ $ $ $ $ $ $ $ $ $ $

292,329 237,601 243,157 202,597 124,698 61,833 60,253 1,222,469 474,113 441,060 85,313 $46,738 63,969 83,738 30,925 29,374 1,255,228

Temp Attorney Temp Attorney Temp Attorney Practice Support Practice Support Legal Analyst Legal Analyst Legal Analyst

$340 $185 -

$175 $165 $175 $200 $200 $350 $200 $275

$181 $195 $225 $225 $370 $315

$195 $195 $240 $240 $425 $375

$185.25 $185.25 $228.00 $228.00 $403.75 $356.25

Subtotal - Others

Grand Total

1,517.50

$

561,923

9,570

$ 3,038,419

19,223

$

6,745,732

10,281.75

$

4,077,985

40,592

$

14,424,058

66
Krevans Copy - SF-2578611 1 of 1

Exhibit 10
9/25/2008 9:18 AM