Vertical Computer Systems, Inc. v. Interwoven, Inc. et al
Filing
31
MOTION to Dismiss Stay or Transfer by Samsung Electronic America Inc, Samsung Electronics Co LTD. (Attachments: # 1 Affidavit of Seo-won Kwon, # 2 Affidavit of Steven ONeill, # 3 Exhibit A to Declaration of Steven ONeill, # 4 Exhibit B to Declaration of Steven ONeill, # 5 Affidavit of Julian Moore, # 6 Exhibit A to Declaration of Julian Moore, # 7 Exhibit B to Declaration of Julian Moore, # 8 Exhibit C to Declaration of Julian Moore, # 9 Exhibit D to Declaration of Julian Moore, # 10 Exhibit E to Declaration of Julian Moore, # 11 Exhibit F to Declaration of Julian Moore, # 12 Exhibit G to Declaration of Julian Moore, # 13 Exhibit H to Declaration of Julian Moore, # 14 Text of Proposed Order)(Findlay, Eric)
____________________________________________________
IN
THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION
VERTICAL COMPUTER SYSTEMS, INC.,
Plaintiff,
V.
§ INTERWOVEN, INC., LG ELECTRONICS
MOBILECOMM U.S.A., INC., LG ELECTRONICS INC., SAMSUNG
CIVIL ACTION NO. 2: lO-CV-490 TJW
ELECTRONICS CO., LTD., SAMSUNG ELECTRONICS AMERICA, INC.,
Defendants.
§ § § § § § § §
DECLARATION OF STEVEN O'NEILL I, Steven O'Neill, declare as follows:
1
.
I am over 1 8 years of age, and am competent to testify as to the matters set
forth herein. I make the following statements based upon my own personal knowledge. 2.
I
am currently a paralegal at
the law firm of Weil, Gotshal & Manges LLP,
counsel to Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc., defendants in the above-captioned case. 3. On February 24, 2011, I went to the Verizon store in Belmont, California.
At that store, Verizon offers the LG Ally Smartphone for sale. 4. Attached as Exhibit A is a true and correct copy of a photograph that I
took showing the display model of the LG Ally Smartphone.
Dockets.Justia.com
§ § § § §
5.
Attached as Exhibit B is a true and correct copy of the promotional
material that the Verizon sales person gave to me regarding the LG Ally Smartphone. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct.
i
\
Executed on February 25, 201 1
r
J
Steven O'Neill
2
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