Polaris IP, LLC v. Google Inc. et al

Filing 532

REPLY to Response to Motion re 415 Emergency MOTION to Strike Portions of Defendants' Invalidity Expert's Report and Defendants' Summary Judgment Briefing and Request for Expedited Briefing filed by Bright Response LLC. (Attachments: # 1 Affidavit of Andrew D. Weiss, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(Weiss, Andrew)

Polaris IP, LLC v. Google Inc. et al

Doc. 532 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 REPLY IN RESPONSE TO PLAINTIFF'S EMERGENCY MOTION TO STRIKE PORTIONS OF DEFENDANTS' INVALIDITY EXPERT REPORT AND DEFENDANTS' SUMMARY JUDGMENT BRIEFING 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 Civil Action No. 2:07-cv-371-TJW JURY

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

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 on July 6, 2010. 3. Exhibit B is a true and correct copy of the relevant excerpts from the

transcript of the deposition of Phil Klahr, taken on July 23, 2010. 4. Exhibit C is a true and correct copy of an email between Jules Adler and

David Perlson regarding the Declaration of Julie Hsu dated April 28, 2010 bearing Bates No. GOOG1689873.

Dockets.Justia.com

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