Goodard v. Google, Inc.

Filing 105

Goodard v. Google, Inc.

Doc. 105

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ROBERT T. HASLAM (Bar No. 71134) [e-mail] MICHAEL K. PLIMACK (Bar No. 133869) [e-mail] CHRISTINE SAUNDERS HASKETT (Bar No. 188053) [e-mail] SAMUEL F. ERNST (Bar No. 223963) [e-mail] COVINGTON & BURLING LLP One Front Street San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] ALAN H. BLANKENHEIMER (Bar No. 218713) [e-mail] LAURA E. MUSCHAMP (Bar No. 228717) [e-mail] JO DALE CAROTHERS (Bar No. 228703) [e-mail] COVINGTON & BURLING LLP 9191 Towne Centre Drive, 6th Floor San Diego, CA 92122-1225 Telephone: [phone] Facsimile: [phone] Attorneys for Defendants and Counterclaimants SAMSUNG ELECTRONICS CO., LTD., SAMSUNG SEMICONDUCTOR, INC., SAMSUNG AUSTIN SEMICONDUCTOR, LLC, SAMSUNG ELECTRONICS AMERICA, INC., SAMSUNG TELECOMMUNICATIONS AMERICA, LLC, SAMSUNG TECHWIN CO., LTD., and SAMSUNG OPTO-ELECTRONICS AMERICA, INC. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA ADVANCED MICRO DEVICES, INC., et al., Plaintiffs and Counterdefendants, v. SAMSUNG ELECTRONICS CO., LTD., et al., Defendants and Counterclaimants. DECLARATION OF CHRISTINE SAUNDERS HASKETT IN SUPPORT OF SAMSUNG'S MOTION FOR LEAVE TO AMEND ITS PRELIMINARY INVALIDITY CONTENTIONS DATE: April 3, 2009 TIME: 9:00 a.m. COURTROOM: 10, 19th Floor JUDGE: The Honorable Susan Illston Case No. 3:08-CV-0986-SI

DECLARATION OF CHRISTINE SAUNDERS HASKETT IN SUPPORT OF MOTION TO AMEND PICS

Dockets.Justia.com

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I, Christine Saunders Haskett declare: 1. I am a partner with the law firm of Covington Burling LLP, counsel to Samsung

Electronics Co., Ltd., Samsung Semiconductor, Inc., Samsung Austin Semiconductor, LLC, Samsung Electronics America, Inc., Samsung Telecommunications America, LLC, Samsung Techwin Co., Ltd., and Samsung Opto-Electronics America, Inc. (collectively "Samsung") in the above-captioned matter. I make this declaration in support of Samsung's Motion for Leave to Amend Its Preliminary Invalidity Contentions in this action, pursuant to Local Rule 3-7. I have personal knowledge of the facts set forth in this declaration, and, if called as a witness, could and would testify thereto. 2. Attached hereto as Exhibit 1 is a true and correct copy of Defendants and

Counterclaimants' Second Amended Preliminary Invalidity Contentions Pursuant to Patent Local Rule 3-3. 3. Attached hereto as Exhibit 2 is a true and correct copy of a letter from Lesli

Rawles to Samuel L. Walling dated December 10, 2008. 4. Attached hereto as Exhibit 3 is a true and correct copy of a letter from William

H. Manning to Michael Plimack dated November 24, 2008. 5. Attached hereto as Exhibit 4 is a true and correct copy of a letter from Samuel F.

Ernst to William H. Manning dated December 8, 2008. 6. Attached hereto as Exhibit 5 is a true and correct copy of a letter from Samuel L.

Walling to Samuel F. Ernst dated December 12, 2008. 7. Attached hereto as Exhibit 6 is a true and correct copy of is a true and correct

copy of an article presented at the 1992 VMIC conference, authored by Kazuyoshi Kamoshida and entitled "Self-Aligned TiN Formation by N2 Plasma Bias Treatment of TiSix." 8. Attached hereto as Exhibit 7 is a true and correct copy of U.S. patent number

5,175,126 issued to Ho et al. on December 29, 1992. 9. Attached hereto as Exhibit 8 is a true and correct copy of U.S. patent number

5,222,047 issued to Matsuda et al. on June 22, 1993.

DECLARATION OF CHRISTINE SAUNDERS HASKETT IN SUPPORT OF MOTION TO AMEND PICS

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SF: 115686-1

10.

Attached hereto as Exhibit 9 is a true and correct copy of U.S. patent number

4,788,667 issued to Nakano et al. on November 29, 1988. 11. Attached hereto as Exhibit 10 is a true and correct copy of U.S. patent number

5,276,649 issued to Hoshita et al. on January 4, 1994. 12. Attached hereto as Exhibit 11 is a true and correct copy of U.S. patent number

5,210,723 issued to Bates et al. on May 11, 1993. 13. Attached hereto as Exhibit 12 is a true and correct copy of U.S. patent number

5,287,324 issued to Nagashima on February 15, 1994. 14. Attached hereto as Exhibit 13 is a true and correct copy of the Notice of

Allowability dated February 5, 1996 from the file history for U.S. 5,559,990. 15. Attached hereto as Exhibit 14 is a true and correct copy of Grooved Gate

MOSFET", authored by Nishimatsu, et. al. and appearing in Proceedings of the 8th Conference (1976 International) on Solid State Devices, Japanese Journal of Applied Physics, Vol. 16 (1977) Supplement 16-1. 16. Attached hereto as Exhibit 15 is a true and correct copy of U.S. patent number

5,248,893 issued to Sakamoto on September 28, 1993. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed at San Francisco, California on February 19, 2009. By: /s/ Christine Saunders Haskett Christine Saunders Haskett

DECLARATION OF CHRISTINE SAUNDERS HASKETT IN SUPPORT OF MOTION TO AMEND PICS

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