TimesLines, Inc v. Facebook, Inc.

Filing 154

MEMORANDUM by Facebook, Inc. in Opposition to motion in limine 137 No. 6 to Bar Dr. Itamar Simonson from Introducing Evidence or Testifying that "Timeline" is Generic (Attachments: # 1 Declaration of Brendan Hughes, # 2 Exhibit A to Declaration)(Willsey, Peter)

IN THE UNITED STATES DISTRICT COURT
FOR THE NORTHERN DISTRICT OF ILLINOIS
EASTERN DIVISION
TIMELINES, INC.
Plaintiff,
v.
FACEBOOK, INC.
Defendant.

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Civil Action No.: 11 CV 6867
HONORABLE JOHN W. DARRAH

DECLARATION OF BRENDAN J. HUGHES IN SUPPORT OF DEFENDANT
FACEBOOK, INC.’S OPPOSITION TO TIMELINES, INC.’S MOTION IN LIMINE NO. 6
I, Brendan J. Hughes, declare:
1.

I am an associate with the law firm Cooley LLP, counsel for Defendant Facebook,

Inc. (“Facebook”) in connection with the above-titled action. I submit this declaration in support
of Facebook’s Opposition to Timelines’ Motion in Limine No. 6. I make this declaration upon
personal knowledge and, if called and sworn as a witness, I could and would testify as to the
matters set forth herein.
2.

Attached hereto as Exhibit A are true and correct copies of cited excerpts from the

deposition of Mr. Itamar Simonson on January 7, 2013 in Palo Alto, California.
I declare under penalty of perjury that the foregoing statements are true and correct.
Executed in Washington, DC this 15th day of April, 2013.

/s/ Brendan J. Hughes
Brendan J. Hughes (pro hac vice)
COOLEY LLP
1299 Pennsylvania Ave., NW, Ste. 700
Washington, DC 20004-2400
Tel: [phone]
Fax: [phone]
Email: [e-mail]

CERTIFICATE OF SERVICE
The undersigned, an attorney, hereby certifies that he served the foregoing
DECLARATION OF BRENDAN J. HUGHES IN SUPPORT OF DEFENDANT
FACEBOOK, INC.’S OPPOSITION TO TIMELINES’ MOTION IN LIMINE NO. 6 by
means of the Court’s CM/ECF System, which causes a true and correct copy of the same to be
served electronically on all CM/ECF registered counsel of record, on April 15, 2013.

Dated: April 15, 2013

/s/ Brendan J. Hughes
Brendan J. Hughes (pro hac vice)
COOLEY LLP
1299 Pennsylvania Ave., NW, Ste 700
Washington, DC 20004-2400
Tel: [phone]
Fax: [phone]
Email: [e-mail]

190550 /DC

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