Goodard v. Google, Inc.

Filing 163

Goodard v. Google, Inc.

Doc. 163

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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 RESPONSIVE CLAIM CONSTRUCTION BRIEF DATE: May 6-7, 2009 TIME: 3:30 p.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 RESPONSIVE CLAIM CONSTRUCTION BRIEF

CASE NO. 3:08-CV-0986 SI

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 Responsive Claim Construction Brief. 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 excerpts from the

Macintosh Desktop Reference produced in this litigation at SAMAMD0247981 SAMAMD0247995, SAMAMD0248032, SAMAMD0248037 - SAMAMD0248040, SAM0248075, SAMAMD0248236, and SAMAMD0248363. 3. Attached hereto as Exhibit 2 is a true and correct copy of excerpts from the IBM

Aptiva Handbook produced in this litigation at SAMAMD0247767 - SAMAMD0247778, and SAMAMD0247794. 4. Attached hereto as Exhibit 3 is a true and correct copy of U.S. Patent No.

5,668,571 to Pai et al. 5. Attached hereto as Exhibit 4 is a true and correct copy of excerpts from the

Microsoft Press Computer Dictionary (3d ed. 1997), definition of the term "control panel." 6. Attached hereto as Exhibit 5 is a true and correct copy of excerpts from the

deposition of Stephen J. Orr taken on November 20, 2008 in this matter. 7. Attached hereto as Exhibit 6 is a true and correct copy of U.S. Patent No.

6,118,493 to Duhault et al. 8. Attached hereto as Exhibit 7 is a true and correct copy of U.S. Patent No.

5,900,868 to Duhault. 9. Attached hereto as Exhibit 8 is a true and correct copy of U.S. Patent No.

5,987,106 to Kitamura.
DECLARATION OF CHRISTINE SAUNDERS HASKETT

IN SUPPORT OF RESPONSIVE CLAIM CONSTRUCTION BRIEF

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CASE NO. 3:08-CV-0986 SI

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10.

Attached hereto as Exhibit 9 is a true and correct copy of U.S. Patent No.

5,761,417 to Henley et al. 11. Attached hereto as Exhibit 10 is a true and correct copy of U.S. Patent No.

5,321,805 to Hayman et al. 12. Attached hereto as Exhibit 11 is a true and correct copy of U.S. Patent No.

5,999,860 to Mintz. 13. Attached hereto as Exhibit 12 is a true and correct copy of the Advisory Action

dated May 17, 1995 from the file history for U.S. Patent No. 5,559,990. 14. Attached hereto as Exhibit 13 is a true and correct copy of the Amendment After

Final Office Action dated September 23, 1994 from the file history for U.S. Patent No. 5,559,990. 15. Attached hereto as Exhibit 14 is a true and correct copy of the Notice of

Allowability dated February 5, 1996 from the file history for U.S. Patent No. 5,559,990. 16. Attached hereto as Exhibit 15 is a true and correct copy of excerpts of Keith

Leaver, Microelectronic Devices (2d ed. 1997). 17. Attached hereto as Exhibit 16 is a true and correct copy of the Office Action

dated May 19, 1992 from the file history for U.S. Patent No. 5,248,893. 18. Attached hereto as Exhibit 17 is a true and correct copy of the Amendment dated

July 7, 1992 from the file history for U.S. Patent No. 5,248,893. 19. Attached hereto as Exhibit 18 is a true and correct copy of the Notice of

Allowability dated March 22, 1993 from the file history for U.S. Patent No. 5,248,893. 20. Attached hereto as Exhibit 19 is a true and correct copy of the Response dated

November 10, 1992 from the file history for U.S. Patent No. 5,248,893. 21. Attached hereto as Exhibit 20 is a true and correct copy of excerpts from the

Microsoft Press Computer Dictionary (2d ed. 1994), definition of the term "bus." 22. Attached hereto as Exhibit 21 is a true and correct copy of the excerpts from the

McGraw-Hill Electronics Dictionary (5th ed. 1994), definition of the term "data."
DECLARATION OF CHRISTINE SAUNDERS HASKETT

IN SUPPORT OF RESPONSIVE CLAIM CONSTRUCTION BRIEF

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SF: 117693-1

23.

Attached hereto as Exhibit 22 is a true and correct copy of excerpts from Jack

Horn, Computer and Data Processing Dictionary and Guide (1966), definition of the term "data." 24. Attached hereto as Exhibit 23 is a true and correct copy of excerpts from The

American Heritage Dictionary (2d ed. 1982), definition of the term "independent." 25. Attached hereto as Exhibit 24 is a true and correct copy of excerpts from

Britannica World Language Dictionary (1964), definition of the term "independent." 26. Attached hereto as Exhibit 25 is a true and correct copy of excerpts from

Webster's Ninth New Collegiate Dictionary, definition of the term "independent." 27. Attached hereto as Exhibit 26 is a true and correct copy of U.S. Patent No.

4,617,482 to Matsuda. 28. Attached hereto as Exhibit 27 is a true and correct copy of U.S. Patent No.

5,289,631 to Koopman et al. 29. Attached hereto as Exhibit 28 is a true and correct copy of excerpts from Que's

Computer User's Dictionary (5th ed. 1994), definition of the term "bus." 30. Attached hereto as Exhibit 29 is a true and correct copy of a letter from Alan H.

Blankenheimer to David Marder dated March 27, 2009. 31. Attached hereto as Exhibit 30 is a true and correct copy of a letter from Alan H.

Blankenheimer to David Marder dated March 28, 2009. 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 March 30, 2009. By: /s/ Christine Saunders Haskett Christine Saunders Haskett

DECLARATION OF CHRISTINE SAUNDERS HASKETT

IN SUPPORT OF RESPONSIVE CLAIM CONSTRUCTION BRIEF

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