Polaris IP, LLC v. Google Inc. et al

Filing 222

MOTION for Protective Order Modification by Yahoo!, Inc.. (Attachments: # 1 Affidavit White Affidavit, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Text of Proposed Order)(White, Jason)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BRIGHT RESPONSE, LLC, Plaintiff, vs. GOOGLE INC., et al., Defendants. DECLARATION OF JASON WHITE IN SUPPORT OF YAHOO! INC.'S MOTION TO MODIFY THE PROTECTIVE ORDER 1. I am a partner with the law firm Howrey LLP, and counsel for Yahoo! Inc. I have Civil Action No. 2:07-cv-371-CE JURY TRIAL DEMANDED

personal knowledge of the pleadings and files in this matter. I have personal knowledge of the documents submitted with this declaration and, if called upon as a witness, could and would testify competently thereto. 2. Attached, as Exhibit 1, is a true and correct copy of the Protective Order entered

the J2 litigation, Docket Entry Number 43. 3. Attached, as Exhibit 2, is a true and correct copy of a letter from me to Mr.

Rafilson dated September 24, 2009. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. Executed on November 5, 2009 in Chicago, Illinois. /s/ Jason White Jason White

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