Timebase Pty Ltd v. Thomson Corporation, The

Filing 195

Declaration of Mark Stignani in Support of 194 Memorandum in Support of Motion filed by Thomson Corporation, The, West Publishing Corporation, West Services. (Razavi, Katherine)

Timebase Pty Ltd v. Thomson Corporation, The

Doc. 195

UNITED STATES DISTRICT COURT DISTRICT OF MINNESOTA TIMEBASE PTY LTD., Plaintiff, vs. THE THOMSON CORPORATION, WEST PUBLISHING CORPORATION, and WEST SERVICES, INC., Defendants. Declaration of Mark Stignani: 1. I, Mark Stignani, am Assistant General Counsel, Intellectual Property for the defendants. I have been in-house counsel for the defendants for 10 years. 2. As Assistant General Counsel, my duties include supervising this litigation. I have supervised this matter since before the case was filed in January, 2007. 3. I have been involved in pre-suit investigation, settlement discussions, discovery, pleadings, motions, strategic direction, and all other aspects of this litigation. I have been in regular communication with the defendants'employees, other in-house counsel, and outside litigation counsel regarding this litigation. 4. To the best of my knowledge, all of my knowledge about non-privileged facts regarding meetings and communications between TimeBase and the defendants has been transmitted to the designated Federal Rule of Civil Procedure 30(b)(6) representative for the defendants.
1

Civil No. 07-1687 (JNE/JJG) DECLARATION OF MARK STIGNANI

Dockets.Justia.com

5. To the best of my knowledge, all of my knowledge about non-privileged facts regarding notice of the patents and knowledge of the patents has been transmitted to the designated Federal Rule of Civil Procedure 30(b)(6) representative for the defendants. 6. To the best of my knowledge, all of my knowledge about non-privileged facts regarding knowledge of documents has been transmitted to the designated Federal Rule of Civil Procedure 30(b)(6) representative for the defendants. 7. To the best of my knowledge, all of my knowledge about non-privileged facts regarding contacts with Ms. Muldoon has been transmitted to the designated Federal Rule of Civil Procedure 30(b)(6) representative for the defendants. 8. To the best of my knowledge, all of my knowledge about non-privileged facts regarding knowledge of patents or the defendants'licensing practices has been transmitted to the designated Federal Rule of Civil Procedure 30(b)(6) representative for the defendants. 9. I understand that one of the topics TimeBase has stated that it wishes to ask me about are the patents on which I am listed as an inventor. Each of those patents, however, relates to work I did at Alliant Techsystems, and is not related to any of Thomson' s products or services. These patents are: 5,524, 545 5,516, 970 5,370, 845 5,363,603 " rocess and apparatus for photolytic degradation of explosives" P " rocess and apparatus for photolytic degradation of explosives" P " rocess and apparatus for photolytic degradation of explosives" P " brasive fluid jet cutting composition and method" A
2

10. I am not aware of any non-privileged, relevant information that I have that is not also known by other individuals, many of whom are already being deposed in connection with this case.

I declare under penalty of perjury that the foregoing is true and correct. Dated: October 11, 2010 /s/ Mark Stignani Mark Stignani

3