Personalized User Model LLP v. Google Inc.

Filing 563

REDACTED VERSION of 557 Declaration, OF JENNIFER D. BENNETT IN SUPPORT OF PUM'S OPENING BRIEF IN SUPPORT OF ITS DAUBERT MOTION TO EXCLUDE PORTIONS OF DR. EDWARD FOX'S NON-INFRINGEMENT REPORT FOR FAI LURE TO APPLY THE COURT'S CLAIM CONSTRUCTION by Personalized User Model LLP, Konig Yochai. (Attachments: # 1 Exhibit 1-3)(Tigan, Jeremy)

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

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

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

DECLARATION OF JENNIFER D. BENNETT IN SUPPORT OF
PUM’S OPENING BRIEF IN SUPPORT OF ITS DAUBERT MOTION
TO EXCLUDE PORTIONS OF DR. EDWARD FOX’S NON-INFRINGEMENT
REPORT FOR FAILURE TO APPLY THE COURT’S CLAIM CONSTRUCTION

Original Filing Date: January 21, 2014
Redacted Filing Date: January 28, 2014

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 Dentons US LLP,
counsel for Plaintiff Personalized User Model, L.L.P. (“PUM”) in this action. I make this
declaration in support of in PUM’s Opening Brief in Support of its Daubert Motion to Exclude
Portions of Dr. Fox’s Non-Infringement Report Because He Did Not Apply The Court’s Claim
Construction.
2.

Attached as Exhibit 1 is a true and correct copy of the Fox Report on Non-

Infringement, dated October 3, 2012.
3.

Attached as Exhibit 2 is a true and correct of the cited excerpts of deposition

transcript from the November 20, 2012 deposition of Edward Fox in this matter.
4.

Attached as Exhibit 3 is a true and correct copy of the cited excerpts from the

January 11, 2011 Claim Construction Hearing Transcript.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed this 21st day of January, 2014 at Dallas, Texas

/s/ Jennifer D. Bennett
Jennifer D. Bennett
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