EMG Technology, LLC v. Apple, Inc.

Filing 104

RESPONSE in Opposition re 91 MOTION to Dismiss EMG Technology, LLCs Claims of Alleged Contributory and Induced Infringement of the 196 Patent of Continental Airlines, Inc. filed by EMG Technology, LLC. (Attachments: # 1 Affidavit Declaration of Shawn G. Hansen, # 2 Exhibit A - FRCP Form 18, # 3 Text of Proposed Order)(Ainsworth, Charles)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION EMG TECHNOLOGY, LLC, Plaintiff, Case No. 6:08-cv-447-LED v. JURY TRIAL DEMANDED APPLE, INC. et al., Defendants. DECLARATION OF SHAWN G. HANSEN IN SUPPORT OF PLAINTIFF EMG TECHNOLOGY, LLC'S RESPONSE IN OPPOSITION TO DEFENDANT CONTINENTAL AIRLINES, INC.'S MOTION TO DISMISS EMG TECHNOLOGY, LLC'S CLAIMS OF ALLEGED CONTRIBUTORY AND INDUCED INFRINGEMENT OF THE `196 PATENT I, Shawn G. Hansen, declare as follows: 1. I am an attorney licensed to practice in the State of California. I am a partner with Manatt, Phelps & Phillips, counsel of record for Plaintiff EMG Technology, LLC ("EMG") in the above-referenced matter. I have personal knowledge of the following facts. If called as a witness, I could and would testify competently to these facts. 2. Attached hereto as Exhibit A is a true and correct copy of Federal Rules of Civil Procedure Form 18 ­ Complaint for Patent Infringement, downloaded on July 24, 2009, from the following URL at the website of the Administrative Office of the U.S. Courts: http://www.uscourts.gov/rules/Usable_Rules_Forms_Civil/CIV18Complaint_for_Patent_Infringement.wpd. I declare under the penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on July 27, 2009 at Palo Alto, California. Respectfully submitted, By: /s/ Shawn G. Hansen Shawn G. Hansen

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