PA Advisors, LLC v. Google Inc. et al

Filing 420

MOTION in Limine (Defendant Yahoo! Inc.'s Motions in Limine) by Yahoo! Inc.. (Attachments: #1 Text of Proposed Order, #2 White Declaration, #3 Exhibit 1 (sealed), #4 Exhibit 2 (sealed), #5 Exhibit 3, #6 Exhibit 4, #7 Exhibit 5 (sealed), #8 Exhibit 6 (filed unsealed and sealed by clerk per atty)(Doan, Jennifer) Modified on 2/24/2010 (sm, ).

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC Plaintiff v. GOOGLE INC., et al. Defendants. ) ) ) ) ) ) ) ) ) )

Civil Action No. 2:07-cv-480 RRR

DECLARATION OF JASON WHITE IN SUPPORT OF DEFENDANT YAHOO! INC.'S MOTIONS IN LIMINE 1. I am a partner with the law firm Howrey LLP, and counsel for Yahoo! Inc. I have

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. Attached, as Exhibit 1, is a true and correct copy of excerpts from Mr. Becker's Expert

Report, dated XXX. 3. Attached, as Exhibit 2, is a true and correct copy of and exhibit from Mr. Becker's Expert

Report, dated January 4, 2010. 4. Attached, as Exhibit 3, is a true and correct copy of excerpts from the December 28, 2009

hearing with the Court. 5. Attached, as Exhibit 4, is a true and correct copy of and email chain between Jason C.

White and Andrew Weiss, dated January 5, 2010.

DECLARATION OF JASON WHITE IN SUPPORT OF YAHOO'S MOTIONS IN LIMINE ­ Page 1

6.

Attached, as Exhibit 5, is a true and correct copy of excerpts from Dr. Rhyne's Expert

Report, dated January 22, 2010. 7. Attached, as Exhibit 6, is a true and correct copy of excerpts from Ilya Geller's

deposition on August 19, 2009. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge and belief. Executed on February 19, 2010 in Austin, Texas. /s/ Jason White Jason White

DECLARATION OF JASON WHITE IN SUPPORT OF YAHOO'S MOTIONS IN LIMINE ­ Page 2