Polaris IP, LLC v. Google Inc. et al

Filing 507

RESPONSE in Opposition re 460 MOTION in Limine Number 1 (Uncharted Prior Art References): Motion to Preclude Defendants' Reliance on or Reference to Uncharted Prior Art References (EZ Reader Manual and CBR Express Manuals) and Hearsay MOTION in Limine Number 1 (Uncharted Prior Art References): Motion to Preclude Defendants' Reliance on or Reference to Uncharted Prior Art References (EZ Reader Manual and CBR Express Manuals) and Hearsay MOTION in Limine Number 1 (Uncharted Prior Art References): Motion to Preclude Defendants' Reliance on or Reference to Uncharted Prior Art References (EZ Reader Manual and CBR Express Manuals) and Hearsay filed by AOL, LLC., Google Inc., Yahoo!, Inc.. (Attachments: # 1 Sistos Decl. ISO Defendants' Response, # 2 Branting Decl ISO Defendants' Response, # 3 Exhibit, # 4 Exhibit, # 5 Exhibit, # 6 Exhibit, # 7 Exhibit, # 8 Exhibit, # 9 Exhibit, # 10 Exhibit, # 11 Exhibit, # 12 Exhibit, # 13 Exhibit, # 14 Exhibit, # 15 Exhibit, # 16 Exhibit, # 17 Exhibit, # 18 Exhibit, # 19 Exhibit, # 20 Exhibit, # 21 Exhibit, # 22 Exhibit, # 23 Exhibit, # 24 Exhibit, # 25 Exhibit, # 26 Exhibit, # 27 Exhibit, # 28 Exhibit)(Sistos, Antonio)

Polaris IP, LLC v. Google Inc. et al

Doc. 507 Att. 12

EXHIBIT H

Dockets.Justia.com

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

BRIGHT RESPONSE, LLC F/K/A POLARIS IP, LLC

NO. 2:07-CV-3 71 -TJW-CE
V.

GOOGLE INC., et al.

JURY, TRIAL DEMANDED

DECLARATION OF JULIE HSU I, Julie Hsu, declare: 1. The facts set forth in this declaration are true and correct and of my personal

knowledge. If called as a witness, I could and would testify competently thereto. 2. I am a named inventor of U.S. Patent No. 6,411,947 ("Automatic Message

Interpretation and Routing System"). 3. I helped to develop Brightware's EZ Reader, which is an application for

automatically interpreting and responding to emails. 4. I co-authored a 1996 case study entitled "BZ Reader: Embedded Al for

Automatic Electronic Mail Interpretation and Routing" (the "BZ Reader article"). The EZ Reader article was submitted to the Association for the Advancement of Artificial Intelligence for publication as part of its Eighth Conference on Innovative Applications of Artificial Intelligence, which took place August 4-8, 1996 in Portland, Oregon. The EZ Reader article is attached as Exhibit A to this declaration. 5. At the time I co-authored the EZ Reader article, I intended for it to accurately

describe our work on the EZ Reader application. 6. I do not recall when the EZ Reader application was deployed.

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Jules Fidler

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I do not recall the AAAI waiving any requirement that case study papers describe applications deployed in the field, i n order to allow the EZ Reader article to be published. I do not recall the article being; written to incorrectly say that EZ Reader was deployed when it was not.

I declare under penalty of perjury of the laws of the United States that the foregoing is true and correct. Executed this day of May, 2010 in NOCSK l t-L ,

Julie Hsu.

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