Polaris IP, LLC v. Google Inc. et al

Filing 615

MOTION for Judgment as a Matter of Law on Invalidity for Failure to Satisfy the Written Description Requirement of 35 USC Sec 112 Para 1 by Google Inc., Yahoo!, Inc.. (Attachments: # 1 Text of Proposed Order, # 2 White Declaration, # 3 Exhibit A, # 4 Exhibit B)(Doan, Jennifer)

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Polaris IP, LLC v. Google Inc. et al D Doc. 615 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION BRIGHT RESPONSE, LLC F/K/A POLARIS IP, LLC Plaintiff v. GOOGLE INC., et al. Defendants DECLARATION OF JASON WHITE IN SUPPORT OF YAHOO! INC.'S MOTION FOR SUMMARY JUDGMENT OF INVALIDITY FOR FAILURE TO SATISFY THE WRITTEN DESCRIPTION REQUIREMENT OF 35 U.S.C § 112¶1 1. I am a partner with the law firm Howrey LLP, and counsel for Yahoo! Inc. I have Case No.: 2:07-cv-371-CE Oral Hearing Requested personal knowledge of the pleadings and files in this matter. I have personal knowledge of the documents submitted with this declaration and, if called upon as a witness, could and would testify competently thereto. 2. 3. Attached, as Exhibit A, is a true and correct copy U.S. Patent No. 6,411,947. Attached, as Exhibit B, is a true and correct copy of an excerpt of Plaintiff's Supplemental Disclosure of Asserted Claims and Infringement Contentions, which was served on January 22, 2010. 4. Attached, as Exhibit C, is a true and correct copy of an excerpt from the transcript of Mr. Cohen's deposition, which was taken on May 20, 2009 in New York, New York. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. Executed on June 29, 2010 in Chicago, Illinois. /s/ Jason White Jason White -1- ockets.Justia.com

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