Polaris IP, LLC v. Google Inc. et al

Filing 465

REPLY to Response to Motion re 391 SEALED MOTION for Summary Judgment on Google's Affirmative Defenses and Counterclaims, 389 SEALED MOTION for Summary Judgment on Defendant AOL's Affirmative Defenses and Counterclaims, 390 SEALED MOTION for Summary Judgment on Defendant Yahoo filed by Bright Response LLC. (Attachments: # 1 Affidavit Wiley Declaration, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H)(Wiley, Elizabeth)

Polaris IP, LLC v. Google Inc. et al

Doc. 465 Att. 1

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BRIGHT RESPONSE, LLC v. GOOGLE INC., et al. NO. 2:07-CV-371-CE JURY

DECLARATION OF ELIZABETH A. WILEY 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 regarding documents and correspondence maintained in the files for this case are true and correct and if called upon to testify I would truthfully testify thereto. 1. Exhibit A is a true and correct copy of Chart A-4 Claim Chart of "EZ

Reader: Embedded AI For Automatic Electronic Mail Interpretation and Routing" to Defendants' operative invalidity contentions. 2. Exhibit B is a true and correct copy of the article entitled "EZ Reader:

Embedded AI for Automatic Electronic Mail Interpretation and Routing". 3. Exhibit C is a true and correct copy of an excerpt of Dr. Branting's chart,

Ex. 2 to Branting report: "Anticipation under 35 U.S.C. § 102 and Obviousness under 35 U.S.C. 203 by EZ Reader." 4. Exhibit D is a true and correct copy of an excerpt of Dr. Branting's Chart

A-69: U.S. Pat. No. 5,581,664 to Allen with the CBR Express Reference Manual as prior art to Asserted Claims of U.S. Patent No. 6,411,947 ("947 Patent"). 5. Exhibit E is a true and correct copy of page one of Dr. Branting's Ex. 1.

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Dockets.Justia.com

6.

Exhibit F is a true and correct copy of an excerpt of the Rebuttal Expert

Report of Dr. V. Thomas Rhyne. 7. Exhibit G is a true and correct copy of an excerpt of the Expert Report of

Harry F. Manbeck, Jr. 8. Exhibit H is a true and correct copy of an excerpt of US Provisional

Application 60/042,494, originally produced as BR000065-96.

I declare under penalty of perjury that the above information is true and correct.

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

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