PA Advisors, LLC v. Google Inc. et al

Filing 257

MOTION to Quash and, MOTION for Protective Order to Preclude Deposition of Johanna Shelton by Google Inc.. (Attachments: #1 Affidavit Declaration of Brian Cannon, #2 Exhibit A to Declaration of Brian Cannon, #3 Exhibit B to Declaration of Brian Cannon, #4 Exhibit C to Declaration of Brian Cannon, #5 Exhibit D to Declaration of Brian Cannon, #6 Exhibit E to Declaration of Brian Cannon, #7 Exhibit F to Declaration of Brian Cannon, #8 Exhibit G to Declaration of Brian Cannon, #9 Exhibit H to Declaration of Brian Cannon, #10 Exhibit I to Declaration of Brian Cannon, #11 Exhibit J to Declaration of Brian Cannon, #12 Exhibit K to Declaration of Brian Cannon, #13 Exhibit L to Declaration of Brian Cannon, #14 Affidavit Declaration of Johanna Shelton, #15 Text of Proposed Order)(Cannon, Brian)

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UNTIED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC, Plaintiff, CASE NO. 2-07CV-480-DF DECLARATION OF JOHANNA SHELTON GOOGLE INC., ET AL., Defendants. DECLARATION OF JOHANNA SHELTON 01980.51319/3053386.2 I, Johanna Shelton, declare: 1. 2. D.C. I have personal knowledge of the facts stated herein. I am Google's Policy Counsel and Legislative Strategist. I work in Washington, My primary responsibility is to advocate public policy positions related to telecommunications, intellectual property, and other areas before policymakers in Washington, D.C. 3. I do not have any knowledge about PA Advisors, LLC, nXn Tech, LLC, Ilya I do not have any technical knowledge of the Geller, or U.S. Patent No. 6,199,067. functionalities of Google Search, Personalized Search, AdWords, AdSense, Gmail, iGoogle, or Toolbar. Nor do I have any information regarding any prior art to U.S. Patent No. 6,199,067. Pursuant to 28 U.S.C. 1746, I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this 13th day of August, 2009 at Washington, DC. /s/ Johanna Shelton Johanna Shelton I hereby attest that Ms. Shelton is unable to submit a holographic signature at this time, but this declaration has been signed using a conformed signature with Ms. Shelton's permission. A holographic signature page will be presented to the Court as soon as it may be acquired. /s/ Andrea Pallios Roberts Andrea Pallios Roberts 2

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