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

Filing 61

DECLARATION re 58 MOTION for Summary Judgment by PEOPLE2PEOPLE GROUP, INC., Phoenix Media/Communications Group, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit I, # 6 Exhibit J)(Donnelly, T.)

UNITED STATES DISTRICT COURT
DISTRICT OF MASSACHUSETTS

FACEBOOK, INC.,

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

Case No. 10-cv-11917-DPW

DECLARATION OF T. CHRISTOPHER DONNELLY
I, T. Christopher Donnelly, state as follows:
1.

I am a partner in the law firm of Donnelly, Conroy and Gelhaar LLP. I am

counsel for defendants Phoenix Media/Communications Group, Inc. (“PMC”) and
People2People Group, Inc. (“P2P”) in the above-captioned action. I have personal knowledge of
the matters stated herein.
2.

Attached hereto as Exhibit A is a copy of United States Patent No. 6,199,157

(“the ‘157 patent”), entitled “System, Method and Medium for Managing Information.”
3.

Attached hereto as Exhibit B is a copy of an article entitled “Clarifying Search: A

User-Interface Framework for Text Searches” that indicates publication in the January 1997
issue of D-Lib Magazine.
4.

Attached hereto as Exhibit C is a copy of an article dated February 1996 entitled

“Alta Vista vs. Lycos.”

5.

Attached hereto as Exhibit D is a copy of an article dated 1997 entitled

“HyperSQL: Web-based Query Interfaces for Biological Databases.”
6.

[redacted]

I declare under the penalty of perjury that the foregoing is true and correct. Executed on
July 29, 2011.

/s/ T. Christopher Donnelly
T. Christopher Donnelly
CERTIFICATE OF SERVICE
I, T. Christopher Donnelly, hereby certify that on this 29th day of July, 2011, I
electronically filed the foregoing Declaration with the Clerk of Court using the CM/ECF system,
which will send notification of such filing(s) to all counsel of record.
/s/ T. Christopher Donnelly
T. Christopher Donnelly

2