Polaris IP, LLC v. Google Inc. et al

Filing 371

RESPONSE in Opposition re 370 MOTION to Stay Yahoo! Inc.'s Motion For A Limited Stay Pending The Resolution Of Yahoo!'s Petition For Writ Of Mandamus To The Federal Circuit filed by Bright Response LLC. (Attachments: # 1 Affidavit of Elizabeth Wiley, # 2 Exhibit A to Wiley Declaration, # 3 Affidavit of Andrew Weiss)(Wiley, Elizabeth)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BRIGHT RESPONSE, LLC, Plaintiff, v. GOOGLE, INC., et al., Defendants. § § § § § § § § §

Civil Action No. 2:07-cv-371-ce JURY TRIAL DEMANDED

DECLARATION OF ELIZABETH A. WILEY IN SUPPORT OF BRIGHT RESPONSE, LLC'S RESPONSE IN OPPOSITION TO YAHOO! INC.'S MOTION FOR A LIMITED STAY PENDING THE RESOLUTION OF YAHOO!'S PETITION FOR WRIT OF MANDAMUS TO THE FEDERAL CIRCUIT My name is Elizabeth A. Wiley. I am a member of the State Bar of Texas, with The Wiley Firm PC, and one of the counsel of record for Bright Response, LLC ("Bright Response") in the above-referenced action. The facts recited below are within my personal knowledge in my capacity as counsel for Bright Response and based on my access to communications concerning and documents produced in this litigation as maintained in client files regarding this litigation. These facts are true and correct and if called upon testify I would truthfully testify regarding these facts. 1. Exhibit A is a true and correct copy of an email from my co-counsel for Bright

Response, Andrew D. Weiss, providing notice to counsel for Yahoo on Monday, June 21, 2010 of the dates and times, including extended hours, that Bright Response's expert intends to be reviewing source code. I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct.

Executed this 22nd day of June, 2010, in Austin, Texas. /s/ Elizabeth A. Wiley Elizabeth A. Wiley

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