Personalized User Model LLP v. Google Inc.

Filing 473

REDACTED VERSION of 456 Declaration re Answering Brief in Opposition to Motion for Summary Judgment of Invalidity (Declaration of Jennifer D. Bennett) by Personalized User Model LLP. (Attachments: # 1 Exhibits A-E)(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 JENNIFER D. BENNETT IN SUPPORT OF PLAINTIFF
PERSONALIZED USER MODEL, L.L.P.’S ANSWERING BRIEF IN OPPOSITION TO
MOTION FOR SUMMARY JUDGMENT OF INVALIDITY

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 JENNIFER D. BENNETT IN SUPPORT OF PLAINTIFF
PERSONALIZED USER MODEL, L.L.P.’S ANSWERING BRIEF IN OPPOSITION TO
GOOGLE'S MOTION FOR SUMMARY JUDGMENT OF INVALIDITY
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 Answering Brief in Opposition to Google’s Motion for
Summary Judgment of Invalidity.
2.

Attached as Exhibit A is a true and correct copy of US Patent No. 6,981,040.

3.

Attached as Exhibit B is a true and correct copy of US Patent No 6,685,276.

4.

Attached as Exhibit C is a true and correct copy of the cited excerpts of the

deposition transcript from the November 7, 2012 deposition of Michael I. Jordan taken in this
matter.
5.

Attached as Exhibit D is a true and correct copy of the cited excerpts of the

deposition transcript from the November 27, 2012 deposition of Jaime G. Carbonell taken in this
matter.
6.

Attached as Exhibit E is a true and correct copy of the cited excerpts of the

deposition transcript from the November 20, 2012 deposition of Edward A. Fox taken in this
matter.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed this 14th day of January 2013, at San Francisco, California
/s/ Jennifer D. Bennett_____________
Jennifer D. Bennett

-2-

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)