Polaris IP, LLC v. Google Inc. et al

Filing 531

SUR-REPLY to Reply to Response to Motion re 392 MOTION for Summary Judgment of Invalidity filed by Bright Response LLC. (Attachments: # 1 Affidavit of Andrew D. Weiss, # 2 Exhibit A, # 3 Exhibit B)(Weiss, Andrew)

Polaris IP, LLC v. Google Inc. et al

Doc. 531 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. DECLARATION OF ANDREW D. WEISS IN SUPPORT OF BRIGHT RESPONSE, LLC'S SURREPLY IN OPPOSITION TO DEFENDANTS' MOTION FOR SUMMARY JUDGMENT OF INVALIDITY UNDER 35 U.S.C. § 102(b), (e), AND § 103(a) I, Andrew D. Weiss, declare and state as follows: 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. 1. Exhibit A is a true and correct copy of the relevant excerpts of the Civil Action No. 2:07-cv-371-TJW JURY

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. 2. Exhibit B is a true and correct copy of the relevant excerpts from the

transcript of the deposition of Bradley Allen, taken on July 21, 2010. I declare under penalty of perjury that the above information is true and correct. Executed this 27th day of July, 2010, in Marshall, Texas. /s/ Andrew D. Weiss Andrew D. Weiss

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