Elan Microelectronics Corporation v. Apple, Inc.

Filing 299

EXHIBITS re 288 Declaration in Support, /Exhibits 9, 10, and 11 to the Declaration of Jane H. Bu in Support of Elan Microelectroncis Corporation's Opposition to Apple, Inc.'s Motion to Compel (Public Versions) filed byElan Microelectronics Corporation. (Attachments: # 1 Exhibit 10, # 2 Exhibit 11)(Related document(s) 288 ) (Bu, Jane) (Filed on 6/17/2011)

EXHIBIT 11

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YITAI HU (SBN 248085)
yitai .hu @ alston .com
SEAN P. DEBRUINE (SBN 168071)
[e-mail]
ELIZABETH H. RADER (SBN 184963)
[e-mail]
JANE HAN BU (SBN 240081)
[e-mail]
JENNIFER LIU (SBN 268990)
[e-mail]
PALANI P. RATHINASAMY (SBN 269852)
[e-mail]

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ALSTON & BIRD LLP

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275 Middlefield Road, Suite 150
Menlo Park, CA 94025-4008
Telephone:
650-838-2000
Facsimile:
650-838-2001

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Attorneys for Plaintiff and Counterdefendant
ELAN MICROELECTRONICS
CORPORATION

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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SAN FRANCISCO DIVISION

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ELAN MICROELECTRONICS
CORPORATION,

Case No. 09-cv-01531 RS (PSG)

DECLARATION OF LILING LAI IN
SUPPORT OF ELAN
MICROELECTRONICS
CORPORATION'S OPPOSITION TO
APPLE, INC.'S MOTION TO COMPEL

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Plaintiff and Counterdefendant,
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v.
APPLE, INC.,
Defendant and Counterplaintiff.
AND RELATED COUNTERCLAIMS

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DECLARATION OF LILING LAI

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Case No. 09-cv-01531 RS (PSG

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I, Liling Lai, declare,
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I am the assistant director of finance department at Elan Microelectronics Corp.

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("Elan"). I have been working at Elan since 1994. I make this declaration based on my personal

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knowledge and information provided by others working at Elan and Elan's records. If called upon

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to testify, I could and would competently testify thereto.
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Elan's financial data, such as sales price, sales quantity and cost, are stored and

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maintained in Elan's ordering database and cost database systems that can be accessed by

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authorized Elan personnel such as myself.
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Data inputted into Elan's database systems are based on, and accurately represent,

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the information contained in the underlying source documents, such as customer invoices, receipts,

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etc.

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I declare under penalty of perjury under the laws of the United States of America and the
laws of Taiwan that the foregoing is true and correct.
Executed this 14th day of June, 2011, in Hsinchu, Taiwan.

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Liling Lai

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DECLARATION OF LILING LAI

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Case No. 09-cv-01531 RS (PSG)