Facebook, Inc. v. Phoenix Media/Communications Group, Inc. et al

Filing 104

DECLARATION re 103 Preliminary Claim Construction Briefs of Arun K. Goel by FNX Broadcasting LLC, PEOPLE2PEOPLE GROUP, INC., Phoenix Media/Communications Group, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G)(Hameline, H.)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS
FACEBOOK, INC.,
Plaintiff,

C.A. No. 1:10-cv-11917-DPW

v.
PHOENIX MEDIA/COMMUNICATIONS
GROUP, INC., PEOPLE2PEOPLE GROUP,
INC., TELE-PUBLISHING, INC., AND FNX
BROADCASTING LLC,

JURY TRIAL DEMANDED

Defendants.

DECLARATION OF ARUN K. GOEL IN SUPPORT OF DEFENDANTS’ PHOENIX
MEDIA/COMMUNICATIONS GROUP, INC., PEOPLE2PEOPLE GROUP, INC., AND
FNX BROADCASTINC LLC’S OPENING CLAIM CONSTRUCTION BRIEF
I, Arun K. Goel, declare:
1.

I am an attorney with Mintz, Levin, Cohn, Ferris, Glovskey, and Popeo, P.C. of

counsel in this action for Defendants Phoenix Media/Communications Group, Inc.,
People2PeopleGroup, Inc., and FNX Broadcasting LLC (“Defendants”). I make this declaration
in support of Defendants’ Opening Claim Construction Brief. I have personal knowledge of the
facts contained within this declaration, and if called as a witness, could testify competently to the
matters contained herein.
2.

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

prosecution history of United States Patent No. 6,199,157 (the “’157 Patent”) produced by
Facebook in this case.
3.

Attached hereto as Exhibit B is a true and correct copy of the ’157 Patent.

4.

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

Facebook, Inc.’s Opening Claim Construction Brief Regarding U.S. Patent 6,199,157 in Wireless
Ink Corp. v. Facebook et al., Case No. 11 Civ. 1751 (PKC) (S.D.N.Y.), which was produced by
Facebook in this case.
5.

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

Declaration in Support of Facebook, Inc.’s Opening Claim Construction Brief Regarding U.S.
Patent 6,199,157 in Wireless Ink Corp. v. Facebook et al., Case No. 11 Civ. 1751 (PKC)
(S.D.N.Y.), which was produced by Facebook in this case.
6.

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

Facebook, Inc.’s Opposition to Wireless Ink Corp.’s Opening Claim Construction Brief
Regarding U.S. Patent 6,199,157 in Wireless Ink Corp. v. Facebook et al., Case No. 11 Civ. 1751
(PKC) (S.D.N.Y.), which was produced by Facebook in this case.
7.

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

transcript from a Markman hearing held in Wireless Ink Corp. v. Facebook et al., Case No. 11
Civ. 1751 (PKC) (S.D.N.Y.), which was produced by Facebook in this case.
8.

Attached hereto as Exhibit G is a true and correct copy of United States Patent

No. 6,314,458.
I declare under penalty of perjury that the foregoing is true and correct. Executed on
January 31, 2013 in San Diego, California.
/s/ Arun K. Goel
Arun K. Goel

2

CERTIFICATE OF SERVICE
I, H. Joseph Hameline, hereby certify that pursuant to Local Rule 5.4(C), this document
has been filed through the ECF system and will be sent electronically to the registered
participants as identified on the Notice of Electronic Filing (NEF). For those parties indicated as
non-registered participants, if any, a paper copy will be sent by facsimile and/or U.S. First Class
Mail on January 31, 2013
/s/ H. Joseph Hameline
H. Joseph Hameline

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