Motorola Mobility, Inc. v. Apple, Inc.

Filing 93

Defendant's MOTION Defendant and Counterclaim-Plaintiff Apple Inc.'s Claim Construction Brief by Apple, Inc.. (Attachments: # 1 Declaration of Christine Saunders Haskett, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20)(Pace, Christopher)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
CASE NO.: 1:10-CV-23580-UU

MOTOROLA MOBILITY, INC.,
Plaintiff,
v.
APPLE INC.,
Defendant.

APPLE INC.,
Counterclaim-Plaintiff,
v.
MOTOROLA, INC. and
MOTOROLA MOBILITY, INC.,
Counterclaim-Defendants.

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DECLARATION OF CHRISTINE SAUNDERS HASKETT
IN SUPPORT OF DEFENDANT AND COUNTERCLAIM-PLAINTIFF
APPLE INC.’S CLAIM CONSTRUCTION BRIEF

I, Christine Saunders Haskett, hereby declare:
1.

I am a partner with the law firm of Covington & Burling LLP, counsel of record

for Apple Inc. (“Apple”) in the above-captioned matter. The matters referenced in this
declaration are based on personal knowledge and if called as a witness I could, and would, testify
competently to these matters.
2.

Attached hereto as Exhibit 1 is a true and correct copy of the June 20, 1997

amendment from the patent prosecution file history of U.S. Patent No. 5,754,119.
3.

Attached hereto as Exhibit 2 is a true and correct copy of the Notice of

Allowability from the patent prosecution file history of U.S. Patent No. 5,754,119.
4.

Attached hereto as Exhibit 3 is a true and correct copy of excerpts of the March 7,

2010 Request for Ex Parte Reexamination Pursuant to 35 U.S.C. § 302 and 37 C.F.R. § 1.510, of
reexam number 09/010,891 (reexam of U.S. Patent No. 6,101,531).
5.

Attached hereto as Exhibit 4 is a true and correct copy of the Order Granting

Request for Ex Parte Reexamination of the ’531 patent, dated May 10, 2010, of reexam number
09/010,891.
6.

Attached hereto as Exhibit 5 is a true and correct copy of Notice of Intent to Issue

Ex Parte Reexamination Certificate, dated September 20, 2010, of reexam number 09/010,891.
7.

Attached hereto as Exhibit 6 is a true and correct copy of the May 21, 1996 Office

Action from the patent prosecution file history of U.S. Patent No. 5,710,987.
8.

Attached hereto as Exhibit 7 is a true and correct copy of the July 25, 1996

Amendment After Final and Response from the patent prosecution file history of U.S. Patent No.
5,710,987.

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9.

Attached hereto as Exhibit 8 is a true and correct copy of the June 2, 1995

Amendment and Response from the patent prosecution file history of U.S. Patent No. 5,710,987.
10.

Attached hereto as Exhibit 9 is a true and correct copy of the August 31, 1995

Office Action from the patent prosecution file history of U.S. Patent No. 5,710,987.
11.

Attached hereto as Exhibit 10 is a true and correct copy of the March 4, 1996

Amendment and Response from the patent prosecution file history of U.S. Patent No. 5,710,987.
12.

Attached hereto as Exhibit 11 is a true and correct copy of the definition of

“address” from Webster’s Third New International Dictionary (unabridged) (1961 ed.).
13.

Attached hereto as Exhibit 12 is a true and correct copy of the definition of

“address” from the IBM Dictionary of Computing (1994 ed.).
14.

Attached hereto as Exhibit 13 is a true and correct copy of U.S. Patent No.

5,577,100.
15.

Attached hereto as Exhibit 14 is a true and correct copy of the August 17, 1998

Amendment from the patent prosecution file history of U.S. Patent No. 6,008,737.
16.

Attached hereto as Exhibit 15 is a true and correct copy of U.S. Patent No.

5,335,278.
17.

Attached hereto as Exhibit 16 is a true and correct copy of the September 13,

1999 Notice of Allowability from the patent prosecution file history of U.S. Patent No.
6,008,737.
18.

Attached hereto as Exhibit 17 is a true and correct copy of the November 9, 1998

Amendment from the patent prosecution file history of U.S. Patent No. 6,008,737.
19.

Attached hereto as Exhibit 18 is a true and correct copy of the January 20, 1999

Amendment from the patent prosecution file history of U.S. Patent No. 6,008,737.

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20.

Attached hereto as Exhibit 19 is a true and correct copy of the May 9, 1995

Amendment from the patent prosecution file history of U.S. Patent No. 5,594,509.
21.

Attached hereto as Exhibit 20 is a true and correct copy of the definition of

“move” from the Concise Oxford English Dictionary (11th ed. 2004).
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct to the best of my knowledge and belief.
Executed on June 28, 2011 at San Francisco, California.

/s/ Christine Saunders Haskett
Christine Saunders Haskett

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