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

Filing 347

MOTION to Stay by AOL Inc, Amazon.com Inc., Google Inc., Match.Com LLC, Match.com, Inc., MySpace Inc., Softlayer Technologies, Inc., Yahoo! Inc.. (Attachments: #1 Affidavit, #2 Exhibit 1A, #3 Exhibit 1B, #4 Exhibit 2, #5 Exhibit 3, #6 Exhibit 4, #7 Exhibit 5, #8 Exhibit 6, #9 Exhibit 7, #10 Exhibit 8, #11 Text of Proposed Order)(Briggs, Todd)

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

Doc. 347 Att. 1

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 DEFENDANTS' MOTION TO STAY THIS ACTION AND DISMISS AMENDED CLAIMS PENDING REEXAMINATION OF U.S. PATENT NO. 5,893,120

Dockets.Justia.com

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 Match.com, LLC and Google Inc. 2. 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. 3. Attached hereto as Exhibit 1 is a true and correct copy of a third party's request

for an ex parte reexamination of U.S. Patent No. 5,893,120. 4. action. 5. Attached hereto as Exhibit 3 is a true and correct copy of Bedrock's request for a Attached hereto as Exhibit 2 is a true and correct copy of the PTO's first office

two-month extension to respond the PTO's first office action. 6. Attached hereto as Exhibit 4 is a true and correct copy of the PTO's grant of

Bedrock's requested extension. 7. Attached hereto as Exhibit 5 is a true and correct copy of Bedrock's response to

the PTO's first office action and an interview summary of Bedrock's interview with three PTO examiners. 8. Attached hereto as Exhibit 6 is a true and correct copy of the Court's Provisional

Claim Construction Order. 9. Attached hereto as Exhibit 7 is a true and correct copy of Bedrock's Opening

Claim Construction Brief. 10. Attached hereto as Exhibit 8 is a true and correct copy of Bedrock's Amended

Infringement Contentions for Google.

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I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on December 21, 2010, at Redwood Shores, California.

/s/ Todd M. Briggs Todd M. Briggs

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