Mirror Worlds, LLC v. Apple, Inc.

Filing 309

MOTION To Limit the Number of Asserted Claims by Apple, Inc.. (Attachments: # 1 Affidavit of Jeffrey G. Randall, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Text of Proposed Order)(Randall, Jeffrey)

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Mirror Worlds, LLC v. Apple, Inc. Doc. 309 Att. 1 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 MOTION TO LIMIT THE NUMBER OF ASSERTED CLAIMS 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. Dockets.Justia.com 2. Attached hereto as Exhibit A is a true and correct copy of a letter dated June 24, 2010 from me to Joseph Diamante, counsel for Mirror Worlds, LLC and Mirror Worlds Technologies, Inc. ("Mirror Worlds"). 3. Attached hereto as Exhibit B is a true and correct copy of an e-mail dated June 30, 2010 from Allan Soobert, counsel for Apple to Alexander Solo, counsel for Mirror Worlds. 4. Attached hereto as Exhibit C is a true and correct copy of an e-mail dated June 30, 2010 from Mr. Soobert to Messrs. Diamante and Solo. 5. Attached hereto as Exhibit D is a true and correct copy of an e-mail dated June 30, 2010 from Mr. Solo to Mr. Soobert. 6. Attached hereto as Exhibit E is a true and correct copy of an e-mail dated July 7, 2010 from Mr. Solo to Mr. Soobert. 7. Attached hereto as Exhibit F is a true and correct copy of an e-mail dated August 2, 2010 from Mr. Soobert to Mr. Solo. 8. Attached hereto as Exhibit G is a true and correct copy of an e-mail dated August 9, 2010 from Mr. Soobert to Mr. Solo. 9. Attached hereto as Exhibit H is a true and correct copy of an Order issued in the matter of Wideveine Tehcnologies, Inc. v. Verimatrix, Inc., No. 2:07-cv-321-RRR/CE (E.D. Tex. Dec. 30, 2009). I declare under penalty of perjury that the foregoing is true and correct. Dated this 13th day of August, 2010. /s/ Jeffrey G. Randall Jeffrey G. Randall LEGAL_US_E # 89285519.1 -2-

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