Rockstar Consortium US LP et al v. Google Inc

Filing 105

Opposed MOTION for the Court to Enter its [Model] Order Focusing Patent Claims and Prior Art to Reduce Costs, to Limit the Number of Asserted Claims, and to Extend the Deadline for the Parties to Comply with P.R. 4-2 by Google Inc. (Attachments: # 1 Affidavit Declaration of Andrea Pallios Roberts, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Text of Proposed Order)(Perlson, David)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
ROCKSTAR CONSORTIUM US LP
AND NETSTAR TECHNOLOGIES LLC,
Plaintiffs,
v.
GOOGLE INC.
Defendant.

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Civil Action No. 13-cv-00893-RG
JURY TRIAL DEMANDED

DECLARATION OF ANDREA PALLIOS ROBERTS IN SUPPORT OF GOOGLE
INC.’S MOTION FOR THE COURT TO ENTER ITS [MODEL] ORDER FOCUSING
PATENT CLAIMS AND PRIOR ART TO REDUCE COSTS, TO LIMIT THE NUMBER
OF ASSERTED CLAIMS, AND TO EXTEND THE DEADLINE FOR THE PARTIES TO
COMPLY WITH P.R. 4-2

01980.00010/6094591.1

I, Andrea Pallios Roberts, declare as follows:
1.

I am an attorney at the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

counsel for Defendant Google Inc. (“Google”) in this matter. I have personal knowledge of the
facts stated herein and if called to testify could and would competently testify thereto.
2.

Attached as Exhibit A is a true and correct copy of cited excerpts of Rockstar’s

P.R. 3-1 contentions.
3.

Attached as Exhibit B is a true and correct copy of an email I received from

Rockstar’s counsel on April 18, 2014.
4.

Attached as Exhibit C is a true and correct copy of an email I received from

Rockstar’s counsel on June 13, 2014.
5.

Attached as Exhibit D is a true and correct copy of a letter I received from

Rockstar’s counsel on June 25, 2014.
6.

Attached as Exhibit E is a true and correct copy of an email I received from

Rockstar’s counsel on July 1, 2014.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed July 2, 2014 in Redwood Shores, California.

___________________________________________
Andrea Pallios Roberts

01980.00010/6094591.1

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