Timebase Pty Ltd v. Thomson Corporation, The

Filing 266

Declaration of Michael Stonebraker in Support of 265 Response in Opposition to Motion filed by Thomson Corporation, The, West Publishing Corporation, West Services. (Attachments: # 1 Exhibit(s) A-1, # 2 Exhibit(s) A-2, # 3 Exhibit(s) A-3, # 4 Exhibit(s) A-4, # 5 Exhibit(s) A-5, # 6 Exhibit(s) A-6, # 7 Exhibit(s) A-7, # 8 Exhibit(s) A-8)(Wagner, Kevin)

UNITED STATES DISTRICT COURT
DISTRICT OF MINNESOTA
TIMEBASE PTY LTD.,

Civil No. 07-1687 (JNE/JJG)
Plaintiff,
DECLARATION OF MICHAEL
STONEBRAKER

vs.
THE THOMSON CORPORATION,
WEST PUBLISHING CORPORATION,
and WEST SERVICES, INC.,
Defendants.

I, Michael Stonebraker, declare as follows:
1. I have been retained in this matter by defendants The Thomson Corporation, West
Publishing Corporation, and West Services, Inc. to provide my opinions and to testify
as an expert witness on various topics, including whether claims 24-48 of U.S. Patent
No. 7,293,228 are invalid for failure to meet the written description requirement of 35
U.S.C. § 112. Among other things, I was asked to prepare an expert report setting
forth my opinion that Claims 24-48 are invalid because they lack a written description
of the claimed “graphical representation of a multidimensional space.”
2. Attached as Exhibit A to my declaration is a true and correct copy of the expert report
I submitted on this issue dated February 28, 2011
3. The statements and opinions made in my expert report are true and correct to the best
of my knowledge and belief, including those relating to scientific issues, which I
believe are true and correct to a reasonable degree of scientific certainty.

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I declare under penalty of perjury of the laws of the United States of America that the
foregoing is true and correct.

Executed remotely on July 20, 2011 from Portland, Oregon,

_________________________________
Michael Stonebraker

fb.us.7050439.03

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