Rockstar Consortium US LP et al v. Google Inc

Filing 276

REPLY to Response to Motion re 220 MOTION to Amend/Correct Invalidity Contentions filed by Google Inc. (Attachments: # 1 Affidavit of Lance Yang, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(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 REPLY IN
SUPPORT OF ITS MOTION TO AMEND INVALIDITY CONTENTIONS

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.

Rockstar Consortium US LP and NetStar Technologies LLC served the complaint

on October 31, 2013. Shortly after and prior to serving its Invalidity Contentions, Google began
its prior art search, which included conducting third-party interviews to locate prior art.
3.

Attached as Exhibit A is true and correct copy of a Menteso webpage located at

http://www.menteso.com/pages/29/services/prior-art-searches. The highlighted portions were
added to the Exhibit A. I accessed this page on November 13, 2014.
4.

Attached as Exhibit B is a true and correct copy of the first 10 search results pages

(i.e., first 100 search results) returned on Google.com for the search query “infoseek” on
November 13, 2014.
5.

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

between Lance Yang and Shawn Blackburn of Susman Godfrey, including emails dated
September 9, 12, 17, 22, and 25, 2014.
6.

Attached as Exhibit D is a true and correct copy of an email from Andrea Roberts

of Quinn Emanuel to Justin Nelson of Susman Godfrey dated October 23, 2014.
7.

Attached as Exhibit E is a document prepared for this Motion that contains true

and correct copies of passages from Excite’s Prospectus, which were also provided in Exhibit 4
(Dkt. No. 220-4) to the Declaration of Lance Yang in Support of Google Inc.’s Motion To
Amend Invalidity Contentions, as well as claim 1 of U.S. Patent No. 7,236,969.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed November 13, 2014 in Los Angeles, California.

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Lance Yang

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