Timebase Pty Ltd v. Thomson Corporation, The
Filing
259
Declaration of Jenna J. Bayer in Support of 258 Response filed by Timebase Pty Ltd. (Attachments: # 1 Placeholder for Exhibits F, G, H, J, K, N and Q, # 2 Exhibit(s) A (Part 1), # 3 Exhibit(s) A (Part 2), # 4 Exhibit(s) B, # 5 Exhibit(s) C (Part 1), # 6 Exhibit(s) C (Part 2), # 7 Exhibit(s) D, # 8 Exhibit(s) E, # 9 Exhibit(s) I, # 10 Exhibit(s) L, # 11 Exhibit(s) M, # 12 Exhibit(s) O, # 13 Exhibit(s) P)(Hosteny, Joseph)
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF MINNESOTA
TIMEBASE PTY LTD.,
Plaintiff,
vs.
THE THOMSON CORPORATION, WEST
PUBLISHING CORPORATION, AND WEST
SERVICES, INC.
Defendants.
I, Jenna J. Bayer, declare:
1.
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File No. 07‐CV‐1687 (JNE/JJG)
DECLARATION OF
JENNA J. BAYER
I am a paralegal for TimeBase in this litigation. I have personal
knowledge of the facts stated in this declaration. I can testify to these facts.
2.
Exhibits A‐Q are listed below and attached and are all true and accurate
copies of the originals, or true and accurate partial copies in instances where only
certain pages are included in the exhibit.
Exhibit Tab
Description of Exhibit
A
TimeBase's U.S. Patent No. 6, 233,592 B1, "System for Electronic
Publishing" (filed as 2 parts).
B
Reexamination Certificate for TimeBase's U.S. Patent No. 6,233,592 C1.
C
TimeBase's U.S. Patent No. 7,293,228, "System for Electronic Publishing"
(filed as 2 parts).
D
Highlighted independent claims of the '592 patent.
E
In re Skvorecz, Slip Op. 08‐1221 (Fed. Cir. Sept. 3, 2009).
F
Pages from Expert Rebuttal Report of Michael Stonebraker, Ph.D. FILED
UNDER SEAL.
Exhibit Tab
Description of Exhibit
G
Defendants' Supplemental Non‐Infringement Claim Charts, 3/19/10.
FILED UNDER SEAL.
H
Thomson numbered (THOM) documents in numerical order. FILED
UNDER SEAL.
I
Letters of June 11, 2010 and July 2, 2010 from Defendants to Plaintiff.
J
Pages from Deposition of Darla Agard. FILED UNDER SEAL.
K
Pages from Deposition of Ophir Frieder. FILED UNDER SEAL.
L
“Five Easy Ways to Retrieve Statutes” available at
http://west.thomson.com/documentation/westlaw/wlawdoc/web/stpl
405.pdf.
M
“Five Easy Ways to Retrieve Regulations” available at
http://west.thomson.com/documentation/westlaw/wlawdoc/web/eas
yregs.pdf.
N
Pages from Deposition of Mark Capaldini. FILED UNDER SEAL.
O
“West’s Response to RFO #CCG‐CALIR‐2010‐001 to Provide Computer
Assisted Legal Research and Investigative Services (CALIR)” available at
http://www.ccg.state.tx.us/contracts/docs/WestTXMSA.pdf.
P
Hosteny Declaration, Doc. No. 17‐3, and Exhibits 14‐16.
Q
Pages from Deposition of David Spencer. FILED UNDER SEAL.
I declare under the penalty of perjury that the foregoing is true and correct.
Executed this 21st day of July, 2011.
/s/ Jenna J. Bayer
2
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