Personalized User Model LLP v. Google Inc.

Filing 314

REDACTED VERSION of 312 Declaration, of Robert Needham by Personalized User Model LLP, Konig Yochai. (Tigan, Jeremy)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE

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PERSONALIZED USER MODEL, L.L.P.,

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Plaintiff,

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v.

c.A. No. 09-525 (LPS)

JURY TRIAL DEMANDED

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GOOGLE, INC.,

PUBLIC VERSION

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Defendant.

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GOOGLE, INC.

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Confidential Version Filed:
August 12, 2011

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Counterclaimant,

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v.

Public Version Filed:
August 18, 2011

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PERSONALIZED USER MODEL, LLP
and YOCHAI KONIG,

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Counterdefendants.

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DECLARA TION OF ROBERT NEEDHAM IN SUPPORT OF PERSONALIZED USER
OGLE INC'S MOTION
TO DISMISS PATENT INFRINGEMENT CLAIMS FOR
LACK OF SUBJECT MATTER JURISDICTION AND OPENING BRIEF IN SUPPORT
OF PUM'S ALTERNATIVE CROSS-MOTION

MODEL, LLP'S ANSWERING BRIEF IN OPPOSITION TO GO

14969016\V-I

I, Robert Needham, declare:
1. I am an associate for SNR DENTON US LLP. I submit this Declaration in
Plaintiff

support of

In Opposition To Google

Personalized User Model, LLP's Answering Brief

Inc's Motion To Dismiss Patent Infringement Claims For Lack of Subject Matter Jurisdiction
and Opening Brief

in Support ofPUM's Alternative Cross-Motion. Unless stated otherwise, I

have personal knowledge of the facts set forth herein.
the

2. Attached as Exhibit 1 is a true and correct copy of

REDACTED

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3. Attached as Exhibit 2 is a true and correct copy of th

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4. Attached as Exhibit 3 is a true and correct copy of excerpts from

REDACTED

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5. Attached as Exhibit 4 is a true and correct copy ofthe PTO Filing Receipt for

U.S. Patent Application No. 12/008,148.

I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.

Executed this 12th day of August, 2011, in D lla

149690 16\V-1

-214969016\V-I

EXHIBIT 1
FULLY REDACTED

EXHIBIT 2
FULLY REDACTED

EXHIBIT 3
FULLY REDACTED

Exhibit 4

CERTIFICATE OF SERVICE
I hereby certify that on August 18, 2011, 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 August 18, 2011, upon the following individuals in the manner indicated:
BY E-MAIL

BY E-MAIL

Richard L. Horwitz
David E. Moore
POTTER ANDERSON & CORROON LLP
1313 N. Market St., 6th Floor
Wilmington, DE 19801

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
Andrea Pallios Roberts
Joshua Lee Sohn
QUINN EMANUEL URQUHART
& SULLIVAN, LLP
50 California Street, 22nd Floor
San Francisco, CA 94111

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