Hovsepian v. Apple, Inc.

Filing 70

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Hovsepian v. Apple, Inc. Doc. 70 1 2 3 4 5 6 7 8 9 10 11 @Zcc^\Vc( :ZccZii $ <dgbVc aae HENNIGAN, BENNETT & DORMAN LLP RODERICK G. DORMAN (SBN 96908) ALAN P. BLOCK (SBN 143783) KEVIN SHENKMAN (SBN 223315) 601 South Figueroa Street, Suite 3300 Los Angeles, California 90017 Phone: (213) 694-1200 Fax: (213) 694-1234 dormanr@hbdlawyers.com blocka@hbdlawyers.com shenkmank@hbdlawyers.com Attorneys for Plaintiff ACACIA MEDIA TECHNOLOGIES CORPORATION UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION 12 13 aVlnZgh adh Vc\ZaZh( XVa^[dgc^V 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 In re ACACIA MEDIA TECHNOLOGIES CORPORATION ) ) ) ) ) ) ) ) ) ) ) ) ) ) Case No. 05 CV 01114 JW DECLARATION OF ALAN P. BLOCK IN SUPPORT OF PLAINTIFF ACACIA MEDIA TECHNOLOGIES CORPORATION'S OPPOSITION TO DEFENDANTS' MOTION FOR RECONSIDERATION OF THE COURT'S CONSTRUCTION OF THE TERM "REMOTE LOCATIONS" DATE: TIME: CTRM: September 8-9, 2005 9:00 a.m. Hon. James Ware CASE NO. 05-CV-01114 JW MDL NO. 1665 BLOCK DECLARATION SUPPORTING ACACIA'S OPPOSITION TO MOTION RE REMOTE LOCATIONS Dockets.Justia.com 1 2 3 4 5 6 7 8 9 10 11 @Zcc^\Vc( :ZccZii $ <dgbVc aae I, Alan P. Block, hereby declare as follows: 1. I am a member of the law firm of Hennigan, Bennett & Dorman LLP, counsel of record for plaintiff Acacia Media Technologies Corporation in this case. I have personal knowledge of the facts stated herein and, if called as a witness, I could and would testify competently thereto. 2. 3. Attached hereto as Exhibit 1 is a true and correct copy of U.S. Patent No. 5,132,992. Attached hereto as Exhibit 2 is a true and correct copy of pages 1-7 of the Court's July 12, 2004 Markman Order. 4. Attached hereto as Exhibit 3 is a true and correct copy of the Petition to Make Special filed on June 17, 1991 during the prosecution of the `992 patent. 5. Attached hereto as Exhibit 4 is a true and correct copy of pages 44-54 of the original patent application for the `992 patent showing original claims 1-32. 6. Attached hereto as Exhibit 5 is a true and correct copy of a Preliminary Amendment 12 13 aVlnZgh adh Vc\ZaZh( XVa^[dgc^V dated April 10, 1996 in connection with the application for U.S. Patent No. 6,002,720. 7. Attached hereto as Exhibit 6 is a true and correct copy of an Office Action dated July 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 24, 1997 in connection with the application for U.S. Patent No. 6,002,720. 8. Attached hereto as Exhibit 7 is a true and correct copy of an Amendment dated November 21, 1997 in connection with the application for U.S. Patent No. 6,002,720. 9. Attached hereto as Exhibit 8 is a true and correct copy of an Office Action dated February 18, 1998 in connection with the application for U.S. Patent No. 6,002,720. 10. Attached hereto as Exhibit 9 is a true and correct copy of an Amendment dated August 6, 1998 in connection with the application for U.S. Patent No. 6,002,720. 11. Attached hereto as Exhibit 10 is a true and correct copy of an Office Action dated March 10, 1999 in connection with the application for U.S. Patent No. 6,002,720. 12. Attached hereto as Exhibit 11 is a true and correct copy of a Reply and Amendment dated June 7, 1999 in connection with the application for U.S. Patent No. 6,002,720. /// /// /// CASE NO. 05-CV-01114 JW MDL NO. 1665 BLOCK DECLARATION SUPPORTING ACACIA'S OPPOSITION TO MOTION RE REMOTE LOCATIONS 1 1 2 3 4 5 6 7 8 9 10 11 @Zcc^\Vc( :ZccZii $ <dgbVc aae 13. Attached hereto as Exhibit 12 is a true and correct copy of U.S. Patent No. 6,002,720. I declare under the penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 25th day of August, 2005, at Los Angeles, California. /s/ Alan P. Block 12 13 aVlnZgh adh Vc\ZaZh( XVa^[dgc^V 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 499488\v1 CASE NO. 05-CV-01114 JW MDL NO. 1665 BLOCK DECLARATION SUPPORTING ACACIA'S OPPOSITION TO MOTION RE REMOTE LOCATIONS 2

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