CROSS ATLANTIC CAPITAL PARTNERS, INC. v. FACEBOOK, INC. et al

Filing 56

Declaration of Heidi L. Keefe Attaching Exhibits to Defendant Facebook's Memorandum in Support of Its Proposed Claim Construction by FACEBOOK, INC., THEFACEBOOK, LLC. (Attachments: # 1 Exhibit Keefe Decl Ex A, # 2 Exhibit Keefe Decl Ex B, # 3 Exhibit Keefe Decl Ex C, # 4 Exhibit Keefe Decl Ex D, # 5 Exhibit Keefe Decl Ex E, # 6 Exhibit Keefe Decl Ex F)(KEEFE, HEIDI)

CROSS ATLANTIC CAPITAL PARTNERS, INC. v. FACEBOOK, INC. et al

Doc. 56

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF PENNSYLVANIA

CROSS ATLANTIC CAPITAL PARTNERS, INC., Plaintiff, v. FACEBOOK, INC. and THEFACEBOOK, LLC, Defendants.

CIVIL ACTION NO. 07-CV- 02768-JP JURY TRIAL DEMANDED

DECLARATION OF HEIDI L. KEEFE ATTACHING EXHIBITS TO DEFENDANT FACEBOOK'S MEMORANDUM IN SUPPORT OF ITS PROPOSED CLAIM CONSTRUCTION

I, Heidi L. Keefe, declare: 1. I am an attorney with White & Case LLP, counsel of record in this action for

Facebook, Inc. and Thefacebook, LLC (collectively "Facebook"). I make this declaration in support of Defendant Facebook's Memorandum in Support of its Proposed Claim Construction. I have personal knowledge of the facts contained within this declaration, and if called as a witness, could testify competently to the matters contained herein. 2. 6,519,629. 3. Attached hereto as Exhibit B is a collection of exemplary claims from the '629 Attached hereto as Exhibit A is a true and correct copy of U.S. Patent No.

patent to allow the Court to analyze the disputed claim terms in use. 4. Attached hereto as Exhibit C is a true and correct copy of the portions of

Webster's II New College Dictionary, Houghton Mifflin Company, 1999 that are cited in Facebook's Memorandum in Support of its Proposed Claim Construction.

PALOALTO 85703 (2K)

Dockets.Justia.com

5.

Attached hereto as Exhibit D is a true and correct copy of the portions of

Microsoft Press Computer Dictionary, Microsoft Press, 1991 that are cited in Facebook's Memorandum in Support of its Proposed Claim Construction. 6. Attached hereto as Exhibit E is a true and correct copy of the portions of

Microsoft Press Computer Dictionary, Microsoft Press, 1999 that are cited in Facebook's Memorandum in Support of its Proposed Claim Construction. 7. Attached hereto as Exhibit F is a true and correct copy of Cybersettle, Inc. v

National Arbitration Forum, Inc., C.A. Fed. (N.J.), 2007. I declare under penalty of perjury that the foregoing is true and correct. Executed on January 11, 2008, at Palo Alto, California.

/s/ Heidi L. Keefe Heidi L. Keefe

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CERTIFICATE OF SERVICE This is to hereby certify that on this 11th day of January, 2008, I caused a true and correct copy of the foregoing document: Declaration of Heidi L. Keefe Attaching Exhibits to Defendant Facebook's Memorandum in Support of its Proposed Claim Construction to be served via this Court's Electronic Filing ("ECF") System, upon the following: Frederick A. Tecce, Esq. McShea/Tecce, P.C. The Bell Atlantic Tower ­ 28th Floor 1717 Arch Street Philadelphia, PA 19103 [e-mail] Thomas J. Duffy, Esq. Patrick J. Keenan, Esq. Duffy & Keenan The Curtis Center, Suite 1150 Independence Square West Philadelphia, PA 19106 [e-mail] Counsel for plaintiff Cross Atlantic Capital Partners, Inc.

/s/ Heidi L. Keefe Heidi L. Keefe

PALOALTO 85703 (2K)