Personalized User Model LLP v. Google Inc.

Filing 120

DECLARATION re 119 Claim Construction Opening Brief -- Declaration of Jennifer D. Bennett -- by Personalized User Model LLP. (Attachments: # 1 Exhibits 1-14)(Tigan, Jeremy)

Personalized User Model LLP v. Google Inc.

Doc. 120

IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE PERSONALIZED USER MODEL, L.L.P., Plaintiff, v. GOOGLE, INC., Defendant. ) ) ) ) ) ) C.A. No. 09-525 (LPS) ) ) )

DECLARATION OF JENNIFER D. BENNETT IN SUPPORT OF PLAINTIFF PERSONALIZED USER MODEL, L.L.P.'S OPENING CLAIM CONSTRUCTION BRIEF I, Jennifer D. Bennett, declare: 1. I am an attorney duly licensed to practice in the State of California, admitted to

practice pro hac vice before this Court, and an associate with the law firm of SNR Denton US LLP, counsel for Plaintiff Personalized User Model, L.L.P. ("P.U.M.") in this action. I make this declaration in support of P.U.M.'s Opening Claim Construction Brief. 2. 3. 4. Attached as Exhibit 1 is a true and correct copy of U.S. Patent No. 6,981,040 B1. Attached as Exhibit 2 is a true and correct copy of U.S. Patent No. 7,685,276 B2. Attached as Exhibit 3 is a true and correct copy of a table summarizing the parties

twelve areas of claim dispute in the order they appear in Plaintiff's Brief. 5. Attached as Exhibit 4 is a true and correct copy of an article found at

http://www.readingonline.org/electronic/JAAL/12-99_Column.html#data. 6. Attached as Exhibit 5 is a true and correct copy of U.S. PAT. & TRADEMARK

OFFICE, U.S. DEPT. OF COMMERCE, MANUAL OF PATENT EXAMINING PROCEDURE 2173.05(e) (8th Ed., rev. July 2010).

Dockets.Justia.com

7.

Attached as Exhibit 6 is a true and correct copy of selected pages from Random

House Webster's Unabridged Dictionary (2d ed. 1999). 8. Attached as Exhibit 7 is a true and correct copy of selected pages from Microsoft

Press Computer Dictionary (3d ed. 1997). 9. Attached as Exhibit 8 is a true and correct copy of selected pages from Dictionary

of Computer Science, Engineering, and Technology (Phillip Laplante ed. 2001). 10. Attached as Exhibit 9 is a true and correct copy of selected pages from Vladimir

S. Cherkassky and Filip M. Mulier, Learning from Data: Concepts, Theory, and Methods (1998). 11. Attached as Exhibit 10 to is a true and correct copy of selected pages from

Webster's Third New International Dictionary (2002). 12. Attached as Exhibit 11 is a true and correct copy of selected pages from The

Oxford English Reference Dictionary (2d ed. 1996). 13. Attached as Exhibit 12 is a true and correct copy of selected pages from The

American Heritage Dictionary of the English Language (1978). 14. Attached as Exhibit 13 is a true an correct copy of an Order from Telecordia

Techs., Inc. v. Alcatel USA, Inc., slip op. at 2 (D. Del. Apr. 21, 2006). 15. Attached as Exhibit 14 is a true and correct copy of an Order from NetRatings,

Inc. v. Coremetrics, Inc., slip op. at 1-2 (D. Del. June 7, 2006). I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this __17th___ day of __November_______, 2010, at Palo Alto, California _/s/ Jennifer D. Bennett_____________ Jennifer D. Bennett

-2-

CERTIFICATE OF SERVICE I hereby certify that on November 17, 2010, I caused the foregoing to be electronically filed with the Clerk of the Court using CM/ECF which will send electronic notification of such filing to all registered participants. Additionally, I hereby certify that true and correct copies of the foregoing were caused to be served on November 17, 2010, upon the following individuals in the manner indicated: BY E-MAIL Richard L. Horwitz David E. Moore POTTER ANDERSON & CORROON LLP 1313 N. Market St., 6th Floor Wilmington, DE 19801 BY E-MAIL Brian C. Cannon QUINN EMANUEL URQUHART & SULLIVAN, LLP 555 Twin Dolphin Dr., 5th Floor Redwood Shores, CA 94065 Charles K. Verhoeven David A. Perlson Antonio R. Sistos Eugene Novikov QUINN EMANUEL URQUHART & SULLIVAN, LLP 50 California Street, 22nd Floor San Francisco, CA 94111

/s/ Jeremy A. Tigan
______________________________________ Jeremy A. Tigan (#5239)