Rockstar Consortium US LP et al v. Google Inc

Filing 142

SUR-REPLY to Reply to Response to Motion re 117 MOTION to Strike Defendant Google Inc.'s Deficient Obviousness Disclosure Under Patent Rule 3-3(B) filed by Google Inc. (Attachments: # 1 Declaration of Lance Yang, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C)(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 LANCE YANG IN SUPPORT OF GOOGLE INC.’S SUR-REPLY
IN OPPOSITION TO PLAINTIFF’S MOTION TO STRIKE GOOGLE INC.’S
OBVIOUSNESS DISCLOSURE UNDER PATENT RULE 3-3(b)

I, Lance Yang, 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 an email correspondence

between Lance Yang of Quinn Emanuel and John Lahad of Susman Godfrey.
3.

Attached as Exhibit B is a true and correct copy of an excerpt of Exhibit B to

Google’s May 23, 2014 Invalidity Contentions..
4.

Attached as Exhibit C is a true and correct copy of an email correspondence

between Lance Yang of Quinn Emanuel and John Lahad of Susman Godfrey.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed September 4, 2014 in Los Angeles, California.

___________________________________________
Lance Yang

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