Rockstar Consortium US LP et al v. Google Inc

Filing 122

MOTION to Strike Plaintiffs' Patent Rule 3-1 Infringement Contentions by Google Inc. Responses due by 8/25/2014 (Attachments: # 1 Affidavit Declaration of Andrea Pallios Roberts, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 12, # 12 Exhibit 13, # 13 Exhibit 14, # 14 Exhibit 15, # 15 Exhibit 16, # 16 Exhibit 17, # 17 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 TO STRIKE PLAINTIFFS’ PATENT RULE 3-1 INFRINGEMENT
CONTENTIONS

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 1 is a true and correct copy of an email from Andrea Pallios

Roberts of Quinn Emanuel to John Lahad of Susman Godfrey, dated April 14, 2014.
3.

Attached as Exhibit 2 is a true and correct copy of an email from John Lahad to

Andrea Pallios Roberts, dated April 18, 2014.
4.

Attached as Exhibit 3 is a true and correct copy of an email from John Lahad to

Andrea Pallios Roberts, dated June 13, 2014.
5.

Attached as Exhibit 4 is a true and correct copy of an email from Andrea Pallios

Roberts to John Lahad, dated June 16, 2014.
6.

Attached as Exhibit 5 is a true and correct copy of a letter from John Lahad to

Andrea Pallios Roberts, dated June 25, 2014.
7.

Attached as Exhibit 6 is a true and correct copy of a letter from Andrea Pallios

Roberts to John Lahad and Justin Nelson of Susman Godfrey, dated June 23, 2014.
8.

Attached as Exhibit 7 is a true and correct copy of a letter from Lance Yang of

Quinn Emanuel to John Lahad, dated June 30, 2014.
9.

Attached as Exhibit 8 is a true and correct copy of an email from Amanda Bonn

of Susman Godfrey to Andrea Pallios Roberts, dated July 2, 2014.
10.

Attached as Exhibit 9 is a true and correct copy of an email from Andrea Pallios

Roberts to Amanda Bonn, dated July 3, 2014.
11.

Exhibit 10 was intentionally omitted.

12.

Exhibit 11 was intentionally omitted.

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13.

Attached as Exhibit 12 is a true and correct copy of Rockstar’s P.R. 3-1

Infringement Claim Chart for U.S. Patent No. 7,236,969.
14.

Attached as Exhibit 13 is a true and correct copy of Rockstar’s P.R. 3-1

Infringement Claim Chart for U.S. Patent No. 7,469,245.
15.

Attached as Exhibit 14 is a true and correct copy of Rockstar’s P.R. 3-1

Infringement Claim Chart for U.S. Patent No. 7,672,970.
16.

Attached as Exhibit 15 is a true and correct copy of Rockstar’s P.R. 3-1

Infringement Claim Chart for U.S. Patent No. 7,895,178.
17.

Attached as Exhibit 16 is a true and correct copy of Rockstar’s P.R. 3-1

Infringement Claim Chart for U.S. Patent No. 7,895,183.
18.

Attached as Exhibit 17 is a true and correct copy of Rockstar’s P.R. 3-1

Infringement Claim Chart for U.S. Patent No. 7,933,883.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed August 8, 2014 in Redwood Shores, California.

___________________________________________
Andrea Pallios Roberts

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