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

Filing 259

MOTION to Compel a Complete Response To Their Sixth Interrogatories by Google Inc., Match.Com LLC. (Attachments: #1 Text of Proposed Order, #2 Affidavit Ex. A, #3 Exhibit A.1, #4 Exhibit A.2, #5 Exhibit A.3, #6 Exhibit A.4, #7 Exhibit A.5, #8 Exhibit A.6)(Briggs, Todd)

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Bedrock Computer Technologies, LLC v. Softlayer Technologies, Inc. et al D Doc. 259 Att. EXHIBIT A ockets.Justia.com 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 i

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