Datatreasury Corporation v. Wells Fargo & Company et al
Filing
763
RESPONSE in Opposition re #740 MOTION for Summary Judgment for Invalidity Based on Indefiniteness of '868 Patent filed by Datatreasury Corporation. (Attachments: #1 Exhibit A#2 Exhibit B#3 Exhibit C#4 Affidavit Declaration of Niclole Reed#5 Text of Proposed Order Order)(Reed, Nicole)
Datatreasury Corporation v. Wells Fargo & Company et al
Doc. 763 Att. 4
Case 2:06-cv-00072-DF-CMC
Document 763
Filed 08/09/2007
Page 1 of 2
IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION ______________________________________ DATATREASURY CORPORATION Plaintiff, v. WELLS FARGO & COMPANY, ET. AL., Defendants ______________________________________
§ § § § § § § §
Civil Action No.:2:06-CV72 (DF) JURY TRIAL DEMAND
DECLARATION OF NICOLE REED IN SUPPORT OF PLAINTIFF'S RESPONSE TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT FOR CLAIM INVALIDITY BASED ON INDEFINITENESS OF U.S. PATENT NO. 5,717,868 I, Nicole Reed, declare: 1. I am a member of the Texas State Bar admitted to appear before this Court and an
attorney with the law firm of Nix, Patterson & Roach, L.L.P., counsel of record for Plaintiff DataTreasury Corporation ("DTC") in this lawsuit. I submit this declaration based on personal knowledge and following a reasonable investigation. If called upon as a witness, I could competently testify to the truth of each statement herein. 2. Attached hereto as Exhibit A is a true and correct copy of U.S. Patent No. 4,448,419 (the
"Telnaes patent" at issue in WMS Gaming, Inc. v. International Game Technology, 184 F.3d 1339, 1348 (Fed. Cir. 1999)). 3. Attached hereto as Exhibit B is a true and correct copy of the Affidavit of David James
dated April 9,2007.
DECLARATION OF NICOLE REED
PAGE 1 OF 2
Dockets.Justia.com
Case 2:06-cv-00072-DF-CMC
Document 763
Filed 08/09/2007
Page 2 of 2
4.
Attached hereto as Exhibit C is a true and correct copy of Plaintiff's proposed
constructions and relevant extrinsic evidence for the five terms at issue in Defendants' Motion for Summary Judgment and Plaintiff's Response. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct. Executed on the 9th day of August, 2007, at Dallas, Texas.
______________________________ NICOLE REED
DECLARATION OF NICOLE REED
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