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

Filing 106

DECLARATION re 105 Preliminary Claim Construction Briefs by Facebook, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E)(Torres, Javier)

UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MASSACHUSETTS

FACEBOOK, INC.
Plaintiff,
v.

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

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

DECLARATION OF JAVIER TORRES
IN SUPPORT OF PLAINTIFF
FACEBOOK, INC.’S OPENING CLAIM CONSTRUCTION BRIEF
I, Javier Torres, declare as follows:
1.

I am an attorney at the law firm of Cooley LLP. I represent Facebook in the

above captioned matter and have been admitted pro hac vice to this Court.

I make this

declaration in support of Facebook’s Opening Claim Construction Brief.
2.

Attached as Exhibit A is a true and correct copy of U.S. Patent No. 6,199,157

(“the ’157 patent”).
3.

Attached as Exhibit B is a true and correct copy of U.S. Patent No. 6,314,458

(“the ’458 patent”).
4.

Attached as Exhibit C is a true and correct copy of the November 17, 2011

Markman hearing transcript in the case Wireless Ink Corp. v. Facebook, Inc., No. 11-CIV-1751
(S.D.N.Y.).
5.

Attached as Exhibit D is a true and correct copy of definitions provided in

Merriam-Webster's Collegiate Dictionary Tenth Edition, copyright 1998.

6.

Attached as Exhibit E is a true and correct copy of definitions provided in the

Collins English Dictionary, Fourth Edition, copyright 1998.
I declare under penalty of perjury that the foregoing is true and correct. Executed on
January 31, 2013 in Palo Alto, CA.
/s/ Javier Torres
Javier Torres

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CERTIFICATE OF SERVICE
I, Javier Torres, 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/ Javier Torres
Javier Torres

1095277 /HN

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