Polaris IP, LLC v. Google Inc. et al

Filing 515

RESPONSE to Motion re 444 MOTION in Limine 6 (joint) MOTION IN LIMINE NO. 6: MOTION TO EXCLUDE EVIDENCE AND ARGUMENT THAT ALLEN DOES NOT DISCLOSE A "NON-INTERACTIVE ELECTRONIC MESSAGE" filed by Bright Response LLC. (Attachments: # 1 DECLARATION, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(Weiss, Andrew)

Polaris IP, LLC v. Google Inc. et al

Doc. 515 Att. 1

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 ANDREW D. WEISS IN SUPPORT OF BRIGHT RESPONSE, LLC'S RESPONSE TO DEFENDANTS' JOINT MOTION IN LIMINE NO. 6: MOTION TO EXCLUDE EVIDENCE AND ARGUMENT THAT ALLEN DOES NOT DISCLOSE A "NON-INTERACTIVE ELECTRONIC MESSAGE" FILED UNDER SEAL I, Andrew D. Weiss, declare and state as follows: 1. I am a member of the State Bar of California and an associate at the firm of Russ,

August & Kabat, counsel of record for Plaintiff Bright Response, LLC in the above-captioned action. I have personal knowledge of the facts set forth herein, and if called upon to testify, could and would testify competently thereto. 2. Exhibit A is a true and correct copy of the relevant excerpts of the REBUTTAL

EXPERT REPORT OF DR. V. THOMAS RHYNE PURSUANT TO RULE 26(a)(2)(B) OF THE FEDERAL RULES OF CIVIL PROCEDURE (VALIDITY OF THE ASSERTED CLAIMS OF THE '947 PATENT), served July 20, 2010. 3. Exhibit B is a true and correct copy of the relevant excerpts of the REPORT OF

DEFENDANTS' EXPERT L. KARL BRANTING, PH.D, J.D. CONCERNING INVALIDITY OF CLAIMS 26, 28, 30, 31, 33, AND 38 OF U.S. PATENT NO. 6,411,947, served July 6, 2010. 3. Exhibit C is a true and correct copy of the relevant excerpts from the Bradley Allen

2995-011_100724 Dec Supp Resp_Defs_MIL_6.doc

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deposition dated July 21, 2010. I declare under penalty of perjury that the above information is true and correct.

Executed this 26th day of July, 2010, in Marshall, Texas.
/s/ Andrew D. Weiss Andrew D. Weiss