Mirror Worlds, LLC v. Apple, Inc.

Filing 251

RESPONSE in Opposition re 229 MOTION for Summary Judgment OF INVALIDITY OF US PATENT NO. 6,613,101 filed by Apple, Inc.. (Attachments: # 1 Text of Proposed Order, # 2 Declaration of Steven K. Feiner Ph.D., # 3 Exhibit 1 to Declaration of Steven K. Feiner Ph.D., # 4 Declaration of Jeffrey G. Randall in Opposition to Motion for Summary Judgment, # 5 Exhibit 1 to Randall Declaration, # 6 Exhibit 2 to Randall Declaration, # 7 Exhibit 3 to Randall Declaration, # 8 Exhibit 4 to Randall Declaration, # 9 Exhibit 5 to Randall Declaration, # 10 Exhibit 6 to Randall Declaration, # 11 Exhibit 7 to Randall Declaration, # 12 Exhibit 8 to Randall Declaration, # 13 Exhibit 9 to Randall Declaration, # 14 Exhibit 10 to Randall Declaration, # 15 Exhibit 11 to Randall Declaration, # 16 Exhibit 12 to Randall Declaration)(Randall, Jeffrey)

Download PDF
Mirror Worlds, LLC v. Apple, Inc. Doc. 251 Att. 4 IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION MIRROR WORLDS, LLC, Plaintiff, v. APPLE INC., Defendant. APPLE INC., Counterclaim Plaintiff, v. MIRROR WORLDS, LLC, MIRROR WORLDS TECHNOLOGIES, INC., Counterclaim Defendants. Civil Action No. 6:08-cv-88 LED JURY TRIAL DEMANDED DECLARATION OF JEFFREY G. RANDALL IN SUPPORT OF APPLE INC.'S OPPOSITION TO MIRROR WORLDS TECHNOLOGIES INC.'S MOTION FOR SUMMARY JUDGMENT OF INVALIDITY OR U.S. PATENT NO. 6,613,101 I, Jeffrey G. Randall, hereby declare as follows: 1. I am a partner at the law firm of Paul, Hastings, Janofsky & Walker LLP, counsel for Defendant and Counterclaim Plaintiff Apple Inc. ("Apple"). The facts stated in this Declaration are true and correct of my own personal knowledge, and if called as a witness, I could and would competently testify thereto. -1Dockets.Justia.com 2. Attached hereto as Exhibit 1 is a true and correct copy of excerpts from Mirror Worlds Technologies, Inc.'s Responsive Claim Construction Brief on U.S. Patent No. 6,613,101, filed January 9, 2010 (Docket No. 161). 3. Attached hereto as Exhibit 2 is a true and correct copy of Apple Inc.'s Reply Claim Construction Brief on U.S. Patent No. 6,613,101 (the "Piles" Patent), filed January 18, 2010 (Docket No. 164). 4. Attached hereto as Exhibit 3 is a true and correct copy of Appeal Brief in Support of Appellants' Appeal to the Board of Patent Appeals and Interferences from the prosecution history for U.S. Patent No. 6,243,724, and bearing production numbers APMW0025579 APMW0025636. 5. 6,613,101 B2. 6. Attached hereto as Exhibit 5 is a true and correct copy of Apple Inc.'s Opening Attached hereto as Exhibit 4 is a true and correct copy of U.S. Patent No. Claim Construction Brief on U.S. Patent No. 6,613,101 (the "Piles" Patent), filed December 7, 2009 (Docket No. 150). 7. Attached hereto as Exhibit 6 is a true and correct copy of excerpts from the prosecution history for U.S. Patent No. 6,243,724, bearing production numbers APMW0025565 APMW0025566. 8. Attached hereto as Exhibit 7 is a true and correct copy of U.S. Patent No. 5,287,448, bearing production numbers APMW0013192 APMW0013202. 9. Attached hereto as Exhibit 8 is a true and correct copy of U.S. Patent No. 5,060,135, bearing production numbers APMW0001020 APMW0001048. -2- 10. Attached hereto as Exhibit 9 is a true and correct copy of a Response to Office Action from the prosecution history for U.S. Patent No. 6,243,724, bearing production numbers APMW0025487 APMW0025491. 11. Attached hereto as Exhibit 10 is a true and correct copy of excerpts from the prosecution history for U.S. Patent No. 6,243,724, bearing production numbers APMW0025709 APMW0025710. 12. Attached hereto as Exhibit 11 is a true and correct copy of the Expert Report of John Levy, Ph.D. Regarding Invalidity of U.S. Patent No. 6,613,101, dated May 20, 2010. 13. Attached hereto as Exhibit 12 is a true and correct copy of excerpts from the Expert Report of John Levy, Ph.D. Regarding Validity, dated June 4, 2010. I declare under penalty of perjury that the foregoing is true and correct. Dated this 22nd day of July, 2010. /s/ Jeffrey G. Randall Jeffrey G. Randall LEGAL_US_E # 88972725 -3-

Disclaimer: Justia Dockets & Filings provides public litigation records from the federal appellate and district courts. These filings and docket sheets should not be considered findings of fact or liability, nor do they necessarily reflect the view of Justia.


Why Is My Information Online?