Personalized User Model LLP v. Google Inc.

Filing 470

REDACTED VERSION of 453 Declaration, re Answering Brief in Opposition to Google's Motion for Summary Judgment Regarding SRI and in Support of PUM's Cross-Motion for Summary Judgment (Declaration of Michael J. Pazzani) by Personalized User Model LLP. (Attachments: # 1 Exhibit A)(Tigan, Jeremy)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PERSONALIZED USER MODEL, L.L.P.,

)
)
Plaintiff,
)
)
v.
)
)
GOOGLE, INC.,
)
)
Defendant.
)
)
)
)
GOOGLE, INC.
)
)
Counterclaimant,
)
)
v.
)
PERSONALIZED USER MODEL, L.L.P. and )
)
YOCHAI KONIG,
)
Counterclaim-Defendants. )

C.A. No. 09-525 (LPS)
PUBLIC VERSION

DECLARATION OF MICHAEL J. PAZZANI IN SUPPORT OF PLAINTIFF
PERSONALIZED USER MODEL, L.L.P.’S ANSWERING BRIEF IN OPPOSITION
TO GOOGLE’S MOTION FOR SUMMARY JUDGMENT REGARDING SRI AND IN
SUPPORT OF PUM’S CROSS-MOTION FOR SUMMARY JUDGMENT

OF COUNSEL:
Marc S. Friedman
SNR Denton US LLP
1221 Avenue of the Americas
New York, NY 10020-1089
[phone]
Jennifer D. Bennett
SNR Denton US LLP
1530 Page Mill Road, Ste. 200
Palo Alto, CA 94304-1125
[phone]
Original Filing Date: January 14, 2013
Redacted Filing Date: January 23, 2013

MORRIS, NICHOLS, ARSHT & TUNNELL LLP
Karen Jacobs Louden (#2881)
Jeremy A. Tigan (#5239)
1201 N. Market Street
P.O. Box 1347
Wilmington, DE 19899-1347
[phone]
[e-mail]
[e-mail]
Attorneys for Personalized User Model, L.L.P.
and Yochai Konig

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
PERSONALIZED USER MODEL, L.L.P.,

)
)
)
Plaintiff,
)
)
v.
)
)
GOOGLE, INC.,
)
)
Defendant.
)
)
)
GOOGLE, INC.
)
)
Counterclaimant,
)
)
v.
)
PERSONALIZED USER MODEL, L.L.P. and )
)
YOCHAI KONIG,
)
Counterclaim-Defendants. )

C.A. No. 09-525 (LPS)
PUBLIC VERSION

DECLARATION OF MICHAEL J. PAZZANI IN SUPPORT OF PLAINTIFF
PERSONALIZED USER MODEL, L.L.P.’S ANSWERING BRIEF IN OPPOSITION
TO GOOGLE’S MOTION FOR SUMMARY JUDGMENT REGARDING SRI AND IN
SUPPORT OF PUM’S CROSS-MOTION FOR SUMMARY JUDGMENT
I, Michael J. Pazzani, declare:
1.

I am the Vice Chancellor for Research and Economic Development and a

Professor of Computer Science & Engineering at the University of California, Riverside. I hold
a Ph.D. in Computer Science, an M.S. in Computer Engineering, and a B.S. in Computer
Engineering, and have been retained as an expert witness 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 Answering Brief
in Opposition to Google’s Motion for Summary Judgment Regarding SRI and in Support of
P.U.M.’s Cross-Motion for Summary Judgment.
2.

On April 10, 2012 I submitted an expert report in which I opined, inter alia, that

the inventions in U.S. Patent Nos. 6,981,040 and 7,685,276 did not result from Dr. Yochai

CERTIFICATE OF SERVICE
I hereby certify that on January 14, 2013, 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 January 14, 2013, 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)