Mirror Worlds, LLC v. Apple, Inc.

Filing 64

RESPONSE in Opposition re #56 MOTION for Leave to File First Amended Answer, Affirmative Defenses, and Counterclaims filed by Mirror Worlds, LLC. (Attachments: #1 Decl of K Gallagher)(Carroll, Otis)

Mirror Worlds, LLC v. Apple, Inc.

Doc. 64 Att. 1

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS T Y L E R DIVISION MIRROR WORLDS, LLC Plaintiff, J U R Y TRIAL D E M A N D E D Civil Action No. 6:08-CV-88 LED

v.
APPLE, INC. Defendant.

DECLARATION OF KENNETH J. GALLAGHER I, Kenneth J. Gallagher, declare as follows:
1.

I was the f o n n e r Treasurer o f Mirror Worlds Technologies, Inc. ("MWT"). I have

personal knowledge o f the facts stated in this Declaration. 2. 3. MWT sold Scopeware products at least as early as 2002. In the fall o f 2 0 0 4 , M W T ceased business operations, including sales o f its

S c o p e w a r e products. 4. From September 2003 until the fall o f 2004, when M W T ceased its business

operations, M W T ' s total sales revenue was less than $50,000 (which includes sales revenue not associated w i t h S c o p e w a r e p r o d u c t s ) . Executed on this 16th day o f January 2009 at New York, N.Y. I declare under penalty o f perjury under the laws o f the United States o f America that the foregoing is true and correct.

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