Rockstar Consortium US LP et al v. Google Inc

Filing 263

RESPONSE in Opposition re 220 MOTION to Amend/Correct Invalidity Contentions filed by NetStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Declaration of Meng Xi, # 2 Exhibit A - Google.com search re InfoSeek IPO filing, # 3 Exhibit B - Part 1 of 3 InfoSeek Corporation's S-1, # 4 Exhibit B - Part 2 of 3 InfoSeek Corporation's S-1, # 5 Exhibit B - Part 3 of 3 InfoSeek Corporation's S-1, # 6 Exhibit C - Zimmerman's Research Guide, # 7 Exhibit D - 11/5/2014 email between ThomsonReuters and Meng Xi, # 8 Exhibit E - 11/5/2014 email between Intelligize and Meng Xi, # 9 Text of Proposed Order)(Xi, Meng)

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

Case No. 2:13-cv-893-JRG-RSP

v.
GOOGLE INC.,

JURY TRIAL DEMANDED

Defendant.

DECLARATION OF MENG XI IN SUPPORT OF PLAINTIFFS’ RESPONSE TO
DEFENDANT’S MOTION FOR LEAVE TO AMEND INVALIDITY CONTENTIONS

I, Meng Xi, declare as follows:
1.

I am attorney at the law firm of Susman Godfrey L.L.P. and I am counsel of

record for Plaintiffs Rockstar Consortium US LP and NetStar Technologies LLC (collectively
“Plaintiffs”) in this action.

I submit this declaration in support of Plaintiffs’ Response to

Defendant’s Motion For Leave to Amend Invalidity Contentions
2.

Attached as Exhibit A is a true and correct copy of the search results page

returned on Google.com for the search query “InfoSeek IPO filing” on November 9, 2014.
3.

Attached as Exhibit B is a true and correct copy of InfoSeek Corporation’s S-1

Registration Statement, Amendment No. 4, filed with the SEC on June 10, 1996.

The

highlighted text appears in Google’s proposed Chart A-40 at Dkt. No. 220-2. I accessed this
filing at http://www.secinfo.com/dr6nd.9Ps.d.htm on November 4, 2014.
4.

Attached as Exhibit C is a true and correct copy of Zimmerman’s Research

Guide, published online by LexisNexis, which explains various methods of obtaining SEC
filings. I accessed this guide at http://law.lexisnexis.com/infopro/zimmermans/disp.aspx?z=1917
on November 4, 2014.
5.

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

between Ernessa Johnson, a research specialist at ThomsonReuters, and myself dated
November 5, 2014.
6.

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

between Rob Peters, a research specialist at Intelligize, and myself dated November 5, 2014.
I declare under penalty of jury under the laws of the United States that the foregoing is
true and correct.
Signed this 10th day of November, 2014, in Austin, Texas.
/s/ Meng Xi
Meng Xi