Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al

Filing 258

RESPONSE in Opposition re #246 SEALED PATENT MOTION TO COMPEL FROM GOOGLE AND MATCH.COM A COMPLETE RESPONSE TO BEDROCK'S FIFTH INTERROGATORY filed by Google Inc., Match.Com LLC. (Attachments: #1 Text of Proposed Order, #2 Affidavit Ex. A, #3 Exhibit Ex. A.1, #4 Exhibit Ex. A.2, #5 Exhibit Ex. A.3, #6 Exhibit Ex. A.4, #7 Exhibit Ex. A.5, #8 Exhibit Ex. A.6)(Briggs, Todd)

Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al

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Doc. 258 Att.

EXHIBIT A

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UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS TYLER DIVISION BEDROCK COMPUTER TECHNOLOGIES LLC, Plaintiff, v. SOFTLAYER TECHNOLOGIES, INC., et al., Defendants. ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) )

CASE NO. 6:09­CV­00269 Hon. Leonard E. Davis

JURY TRIAL DEMANDED

DECLARATION OF TODD M. BRIGGS IN SUPPORT OF GOOGLE AND MATCH.COM'S OPPOSITION TO BEDROCK'S MOTION TO COMPEL A COMPLETE RESPONSE TO ITS FIFTH INTERROGATORY AND GOOGLE AND MATCH.COM'S CROSS-MOTION TO COMPEL A COMPLETE RESPONSE TO THEIR SIXTH INTERROGATORIES

I, Todd M. Briggs, declare as follows: 1. I am a member of the bar of the State of California and a partner at Quinn

Emanuel Urquhart & Sullivan, LLP, attorneys for Google Inc. and Match.com, LLC. Each of the following statements is made of my own personal knowledge, and if called upon to testify thereto, I could and would competently do so. 2. Attached hereto as Exhibit A.1 is a true and correct copy of Defendant Match.com

LLC's First Set of Interrogatories to Plaintiff Bedrock Computer Technologies LLC, dated Dec. 17, 2009. 3. Attached hereto as Exhibit A.2 is a true and correct copy of Defendant Google

Inc.'s First Set of Interrogatories to Plaintiff Bedrock Computer Technologies LLC, dated Dec. 17, 2009. 4. Attached hereto as Exhibit A.3 is a true and correct copy of Plaintiff's Responses

to Match.com LLC's First Set of Interrogatories (1-6), dated Jan. 22, 2010. 5. Attached hereto as Exhibit A.4 is a true and correct copy of Plaintiff's Responses

to Google Inc.'s First Set of Interrogatories (1-6), dated Jan. 22, 2010. 6. Attached hereto as Exhibit A.5 is a true and correct copy of Plaintiff's First

Supplemental Responses to Match.com LLC's First Set of Interrogatories (1-6), dated Mar. 5, 2010. 7. Attached hereto as Exhibit A.6 is a true and correct copy of Plaintiff's First

Supplemental Responses to Google Inc.'s First Set of Interrogatories (1-6), dated Mar. 5, 2010. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on Aug. 2, 2010 at Redwood Shores, California. /s/ Todd M. Briggs__________ Todd M. Briggs

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