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

Filing 763

RESPONSE in Opposition re #756 SEALED PATENT MOTION TO PRECLUDE RELIANCE ON DOCUMENTS AND FACTS RELATED TO PERFORMANCE TESTING PRODUCED BY YAHOO AND SOFTLAYER AFTER CLOSE OF DISCOVERY filed by Yahoo! Inc.. (Attachments: #1 Affidavit Declaration of B. James, #2 Exhibit 1)(Chaikovsky, Yar)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
TYLER DIVISION

BEDROCK COMPUTER TECHNOLOGIES
LLC,
Plaintiff,
v.
SOFTLAYER TECHNOLOGIES, INC., et al.,
Defendants.

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Case No. 6:09-cv-269
JURY TRIAL DEMANDED
The Honorable Leonard E. Davis

DECLARATION OF BRYAN K. JAMES IN SUPPORT OF YAHOO!’S RESPONSE IN
OPPOSITION TO BEDROCK’S MOTION TO PRECLUDE RELIANCE ON
DOCUMENTS AND FACTS RELATED TO PERFORMANCE TESTING PRODUCED
BY YAHOO! AFTER CLOSE OF DISCOVERY
I, Bryan K. James, declare as follows:
1.

I am an attorney in good standing with the law firm of McDermott, Will &

Emery, counsel of record for Defendant Yahoo! Inc. I am over eighteen years of age, of sound
mind, and am competent in all respects to make this declaration. Unless otherwise stated, I have
personal knowledge of the facts set forth in this declaration and if called as a witness, could
testify competently to such facts under oath.
2.

Attached hereto as Exhibit 1 is a true and correct copy of a portion of the

transcripts from the February 10, 2011 deposition of Dr. Mark Jones.
Per 28 U.S.C. § 1746, I declare under penalty of perjury under the laws of the United
States that the foregoing is true and correct.

Executed on April 24, 2011 at Tyler, Texas.
/s/ Bryan K. James____________________
Bryan K. James
California State Bar No. 260753
MCDERMOTT WILL & EMERY LLP
275 Middlefield Road, Suite 100
Menlo Park, CA 94025
Tel: [phone]
Fax: [phone]
E-mail: [e-mail]
ATTORNEY FOR DEFENDANT
Yahoo! Inc.

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