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)

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____________________________________________________ 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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