PA Advisors, LLC v. Google Inc. et al

Filing 456

RESPONSE in Opposition re #431 Seventh SEALED MOTION Defendants' Motion in Limine No. 7 filed by PA Advisors, LLC. (Attachments: #1 Affidavit of Patrick Anderson, #2 Exhibit A, #3 Exhibit B, #4 Exhibit C, #5 Exhibit D, #6 Exhibit E)(Anderson, Patrick)

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PA Advisors, LLC v. Google Inc. et al Doc. 456 Att. 1 ANDERSON DECLARATION N THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION PA ADVISORS, LLC v. GOOGLE INC., et al. NO. 2:07-cv-480-RRR JURY TRIAL DEMANDED DECLARATION OF PATRICK R. ANDERSON IN SUPPORT OF nXn TECH, LLC'S RESPONSE TO GOOGLE INC.'S MOTION IN LIMINE NO. SEVEN My name is Patrick R. Anderson. I am a member of the State Bar of Michigan, with Patrick R. Anderson PLLC, and one of the counsel of record for nXn Tech, LLC (f/k/a PA Advisors, LLC) ("nXn") in the above-referenced action. I am one of the counsel of record in the above referenced action. The facts recited below are within my personal knowledge in my capacity as counsel for nXn and based on my access to documents produced in this litigation as maintained in client files regarding this litigation. These facts are true and correct and if called upon to testify I would truthfully testify regarding these facts. 1. Exhibit A is a true and correct copy of the Defendant Google Inc.'s Answer, Affirmative Defenses and Counterclaims to PA Advisors LLC's Second Amended Complaint for Patent Infringement, served September 10, 2009. 2. Exhibit B is a true and correct copy of Yahoo! Inc.'s Answer, Affirmative Defenses, and Counterclaims to Plaintiff's Second Amended Complaint, served September 10, 2009. 1 3. Exhibit C is a true and correct copy of the plaintiff's Second Amended Complaint for Patent Infringement. 4. Exhibit D is a true and correct copy of Nichia Corp. v. Seoul Semiconductor, Ltd, No.C-06-0162-MMC, 2006 U.S. Dist LEXIS 29959 at *6 (N.D. Cal May 9, 2006). 5. Exhibit E is a true and correct copy of the Transcript of December 28, 2009 Hearing for Pretrial Conference before the Honorable Randall R. Rader, Judge. I declare under penalty of perjury that the statements in this declaration are true and correct. Executed this 25th day of February, 2010, in Dallas, Texas. /s/ Patrick. R. Anderson Patrick R. Anderson 2

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