Skyhook Wireless, Inc. v. GOOGLE, INC.

Filing 50

AFFIDAVIT in Support re 49 Preliminary Claim Construction Briefs. (Attachments: # 1 Exhibit 1, # 2 Exhibit 2, # 3 Exhibit 3, # 4 Exhibit 4, # 5 Exhibit 5, # 6 Exhibit 6, # 7 Exhibit 7, # 8 Exhibit 8, # 9 Exhibit 9, # 10 Exhibit 10, # 11 Exhibit 11, # 12 Exhibit 12, # 13 Exhibit 13, # 14 Exhibit 14, # 15 Exhibit 15)(Lu, Samuel)

IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
SKYHOOK WIRELESS, INC.,
Plaintiff and
Counterclaim-Defendant,
v.
GOOGLE INC.,
Defendant and
Counterclaimant.

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Case No. 1:10-cv-11571-RWZ
AFFIDAVIT OF LINA F. SOMAIT IN
SUPPORT OF PLAINTIFF SKYHOOK
WIRELESS, INC.'S OPENING CLAIM
CONSTRUCTION BRIEF

I, Lina F. Somait, declare as follows:
1.

I am an attorney at the law firm of Irell & Manella LLP ("Irell & Manella"),

counsel to plaintiff Skyhook Wireless, Inc. ("Skyhook"). I am a member in good standing of the
State Bar of California, and have been admitted to the Bar of this Court for the purpose of this
litigation. I submit this declaration in connection with Skyhook's Opening Claim Construction
Brief. I have personal knowledge of the matters set forth in this declaration and, if called as a
witness, could testify to its contents.
2.

Attached hereto as Exhibit 1 is a true and correct copy of U.S. Patent No.

7,305,245.
3.

Attached hereto as Exhibit 2 is a true and correct copy of U.S. Patent No.

7,433,694.
4.

Attached hereto as Exhibit 3 is a true and correct copy of U.S. Patent No.

7,414,988 (the "'988 patent").
5.
7,474,897.

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Attached hereto as Exhibit 4 is a true and correct copy of U.S. Patent No.

6.

Attached hereto as Exhibit 5 is a true and correct copy of excerpts from The

Compact Oxford English Dictionary (2d ed. 1991) produced by Google Inc. in this litigation,
bates marked GSHFED_0004444, GSHFED_0004459 and GSHFED_0004465.
7.

Attached hereto as Exhibit 6 is a true and correct copy of excerpts from Webster's

Third New International Dictionary Unabridged (2002) produced by Skyhook in this litigation,
bates marked SKYFED013807–10.
8.

Attached hereto as Exhibit 7 is a true and correct copy of excerpts from The

American Heritage Science Dictionary (2005) produced by Skyhook in this litigation, bates
marked SKYFED013654–56.
9.

Attached hereto as Exhibit 8 is a true and correct copy of excerpts from John R.

Vacca, Wireless Data Demystified (2003) produced by Skyhook in this litigation, bates marked
SKYFED013785–86 and SKYFED013792–93.
10.

Attached hereto as Exhibit 9 is a true and correct copy of excerpts from Merriam-

Webster's Collegiate Dictionary (10th ed. 2001) produced by Skyhook in this litigation, bates
marked SKYFED013717–19.
11.

Attached hereto as Exhibit 10 is a true and correct copy of excerpts from The

Cassell Dictionary and Thesaurus (1999) produced by Skyhook in this litigation, bates marked
SKYFED013822–33.
12.

Attached hereto as Exhibit 11 is a true and correct copy of excerpts from The

American Heritage College Dictionary (3rd ed. 1997) produced by Skyhook in this litigation,
bates marked SKYFED013732–33, SKYFED013736 and SKYFED013815–17.

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13.

Attached hereto as Exhibit 12 is a true and correct copy of excerpts from Wiley

Electrical and Electronics Engineering Dictionary (2004) produced by Skyhook in this
litigation, bates marked SKYFED013811–12 and SKYFED013814.
14.

Attached hereto as Exhibit 13 is a true and correct copy of excerpts from

McGraw-Hill Dictionary of Scientific and Technical Terms (4th ed. 1989) produced by Skyhook
in this litigation, bates marked SKYFED013711–12 and SKYFED013714.
15.

Attached hereto as Exhibit 14 is a true and correct copy of excerpts from The

IEEE Standard Dictionary of Electrical and Electronics Terms (6th ed. 1996) produced by
Skyhook in this litigation, bates marked SKYFED013737–39.
16.

Attached hereto as Exhibit 15 is a document that identifies corresponding

structures for disputed claim terms in the '988 patent if the Court finds one of more of these
claim terms to constitute means plus function claim terms.

Executed on September 14, 2011, in Los Angeles, California.
I declare under penalty of perjury under the laws of the United States of America that the
forgoing is true and correct.

/s/ Lina F. Somait
Lina F. Somait

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Certificate of Service
I, Samuel K. Lu, hereby certify that this document filed through the ECF system will be sent
electronically to the registered participants as identified on the Notice of Electronic Filing (NEF)
on September 14, 2011.

/s/ Samuel K. Lu
Samuel K. Lu

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