Xerox Corporation v. Google Inc. et al

Filing 143

DECLARATION re 141 Claim Construction Opening Brief [DECLARATION OF ANDREA PALLIOS ROBERTS] by Google Inc., Right Media LLC, Yahoo! Inc.. (Attachments: # 1 Exhibit 1-4)(Moore, David)

Xerox Corporation v. Google Inc. et al

Doc. 143

UNITED STATES DISTRICT COURT DISTRICT OF DELAWARE XEROX CORPORATION, Plaintiff-Counterclaim Defendant, v. GOOGLE INC., YAHOO! INC., RIGHT MEDIA INC., RIGHT MEDIA LLC, YOUTUBE, INC., AND YOUTUBE, LLC, Defendants-Counterclaim Plaintiffs, C.A. No. 10-136-LPS-MPT JURY TRIAL DEMANDED

DECLARATION OF ANDREA PALLIOS ROBERTS I, Andrea Pallios Roberts, declare as follows: 1. I am an attorney authorized to practice law in the State of California. I am an associate at the

law firm of Quinn Emanuel Urquhart & Sullivan, LLP, counsel of record for Google Inc. and YouTube LLC in this matter. I have personal knowledge of the facts stated herein and if called to testify could and would competently testify thereto. 2. Attached as Exhibit 1 is a true and correct copy of pages from Random House Unabridged

Dictionary (2d Ed. 1993), as cited on page 13 of Defendants' Opening Claim Construction brief. (Dkt. 141.) 3. Attached as Exhibit 2 is a true and correct copy of pages from The American Heritage

Dictionary of The English Language (2009), as cited on page 8 of Defendants' Opening Claim Construction brief. (Dkt. 141.)

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Attached as Exhibit 3 is a true and correct copy of pages from Webster's Ninth New

Collegiate Dictionary (1990), as cited on page 8 of Defendants' Opening Claim Construction brief. (Dkt. 141.) 5. Attached as Exhibit 4 is a true and correct copy of pages from Webster's Third New Int'l

Dictionary, Unabridged (2002), as cited on pages 13 and 17 of Defendants' Opening Claim Construction brief. (Dkt. 141.)

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

Executed this 29th day of March, 2011, in Redwood Shores, California.

By Andrea Pallios Roberts

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE CERTIFICATE OF SERVICE I, David E. Moore, hereby certify that on March 29, 2011, the attached document was electronically filed with the Clerk of the Court using CM/ECF which will send notification to the registered attorney(s) of record that the document has been filed and is available for viewing and downloading. I hereby certify that on March 29, 2011, the attached document was electronically mailed to the following person(s)

Lawrence C. Ashby John G. Day Lauren E. Maguire ASHBY & GEDDES 500 Delaware Avenue, 8th Floor Wilmington, DE 19899 [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff Xerox Corporation

Richard J. Stark Andrei Harasymiak Peter A. Emmi Scott A. Leslie CRAVATH, SWAINE & MOORE LLP Worldwide Plaza 825 Eighth Avenue New York, NY 10019 [e-mail] [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff Xerox Corporation Matthew B. Lehr Anthony I. Fenwick David J. Lisson Jeremy M. Brodsky DAVIS POLK & WARDELL LLP 1600 El Camino Real Menlo Park, CA 94025 [e-mail]
[e-mail]

Jack B. Blumenfeld Maryellen Noreika Jeremy A. Tigan MORRIS, NICHOLS, ARSHT & TUNNELL LLP 1201 North Market Street Wilmington, DE 19899 [e-mail] [e-mail] [e-mail] Attorneys for Defendants Right Media LLC and Yahoo! Inc.

[e-mail] [e-mail] Attorneys for Defendants Right Media LLC and Yahoo! Inc.

/s/ David E. Moore Richard L. Horwitz David E. Moore POTTER ANDERSON & CORROON LLP [phone] [e-mail] [e-mail]
967858 / 35374