Rockstar Consortium US LP et al v. Google Inc

Filing 282

SUR-REPLY to Reply to Response to Motion re 220 MOTION to Amend/Correct Invalidity Contentions filed by NetStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Affidavit of Meng Xi, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E)(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’ SUR-REPLY IN
OPPOSITION TO 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’ Sur-Reply in
Opposition to Google’s Motion For Leave to Amend Invalidity Contentions
2.

Attached as Exhibit A is a true and correct copy of Google Inc.’s Notice Pursuant

to 35 U.S.C. § 282 filed on October 2, 2009 as Docket No. 191 in Function Media, L.L.C. v.
Google, Inc., Case No. 2:07-cv-279-RSP, in the United States District Court for the Eastern
District of Texas (Marshall Division).
3.

Attached as Exhibit B is a true and correct copy of the attorneys list in Function

Media, L.L.C. v. Google, Inc., Case No. 2:07-cv-279-RSP, in the United States District Court for
the Eastern District of Texas (Marshall Division).

I accessed this list through Pacer on

November 17, 2014.
4.

Attached as Exhibit C is a true and correct copy of U.S. Patent No. 8,335,712

titled “Minimizing Ad Production Costs for Print Advertisers,” assigned to Google Inc.
5.

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

between Rob Peters, a research specialist at Intelligize, and myself dated November 17, 2014.
6.

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

between Ernessa Johnson, a research specialist at Thomson Reuters, and myself dated November
17, 2014.
I declare under penalty of jury under the laws of the United States that the foregoing is
true and correct.
Signed this 17th day of November, 2014, in Lafayette, California.
/s/ Meng Xi
Meng Xi

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