Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 712

MOTION to Compel DISCOVERY FROM ADOBE SYSTEMS, INC. REGARDING INVESTMENT/LICENSING AGREEMENTS WITH INTELLECTUAL VENTURES' ENTITIES by Eolas Technologies Incorporated. (Attachments: # 1 Declaration of Rosemary Snider, # 2 Exhibit A, # 3 Exhibit B, # 4 Exhibit C, # 5 Exhibit D, # 6 Exhibit E, # 7 Exhibit F, # 8 Exhibit G, # 9 Exhibit H, # 10 Exhibit I, # 11 Exhibit J, # 12 Exhibit K, # 13 Exhibit L, # 14 Text of Proposed Order)(McKool, Mike)

IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

TYLER DIVISION

Eolas Technologies Incorporated,

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Plaintiff,
vs.
Adobe Systems Inc., Amazon.com, Inc.,
Apple Inc., Blockbuster Inc., CDW Corp.,
Citigroup Inc., eHay Inc., Frito-Lay, Inc.,
The Go Daddy Group, Inc., Google Inc.,
J.C. Penney Company, Inc., JPMorgan
Chase & Co., New Frontier Media, Inc.,
Office Depot, Inc., Perot Systems Corp.,
Playboy Enterprises International, Inc.,
Rent-A-Center, Inc., Staples, Inc., Sun
Microsystems Inc., Texas Instruments
Inc., Yahoo! Inc., and YouTube, LLC
Defendants.

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Civil Action No. 6:09-cv-446

JURY TRIAL

DECLARATION OF ROSEMARY SNIDER IN SUPPORT OF EOLAS'

MOTION TO COMPEL DISCOVERY FROM ADOBE SYSTEMS, INC.

REGARDING INVESTMENT LICENSING AGREEMENTS

WITH INTELLECTUAL VENTURES ENTITIES

I, Rosemary Snider, do state and declare as follows:
I.

I am an attorney with the law firm of McKool Smith PC (McKool Smith), counsel

for Plaintiff Eolas Technologies Incorporated (Eolas) in this action. I make this declaration in
support of Eolas' Motion to Compel Discovery from Adobe Systems Inc. Regarding Investment
Licensing Agreements With Intellectual Ventures Entities. Unless otherwise stated, the matters
contained in this declaration are of my own personal knowledge and, if called as a witness, I
could and would testify competently to the matters set forth herein.
2.

Attached hereto as Exhibit A is a true and correct copy of a document titled

Intellectual Ventures Overview printed from Intellectual Ventures' website.

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3.

Attached hereto as Exhibit B is a true and correct copy of a document titled

Global Licensing Overview printed from Intellectual Ventures' website.
4.

Attached hereto as Exhibit C is a true and correct copy of a document titled

Products and Services printed from Intellectual Ventures' website.
S.

Attached hereto as Exhibit D is a true and correct copy of a document titled

Licensing printed from Intellectual Ventures' website.
6.

Attached hereto as Exhibit E is a true and correct copy of a document titled

Notice of Transaction Pursuant to Corporation Code Section 2S I02(f) regarding Invention
Investment Fund II, LLC.
7.

Attach~d

hereto as Exhibit F is a true and correct copy of a document titled

Defendants' Certificate of Interested Entities or Persons Pursuant to Civil Local Rule 3-16
F.R.C.P. 7. 1, filed in Xilinx, Inc. v. Invention Investment Fund I, LP, in Case No. 11-cv-0671-SI,
in the U.S. District Court in the Northern District of California.
8.

Attached hereto as Exhibit G is a true and correct copy of a letter from Mr. Josh

Budwin to Mr. David Healey, dated May 20, 20 II, in this matter.
9.

Attached hereto as Exhibit H is a true and correct copy of an email from Mr.

Budwin to Ms. Mehta Sonal et aI., dated June 6,2011, in this matter.
10.

Attached hereto as Exhibit I is a true and correct copy of an email from Mr.

Healey to Mr. Budwin et aI., dated June 10,2011, in this matter.
11.

Attached hereto as Exhibit J is a true and correct copy of an email from Mr.

Healey to Mr. Budwin et a1., dated June 16,2011, in this matter.
12.

Attached hereto as Exhibit K is a true and correct copy of an email from Mr.

Donahey Teague to Mr. Budwin et aI., dated June 17, 2011, in this matter.

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13.

Attached hereto as Exhibit L is a true and correct copy of an email from Mr.

Christopher Mierzejewski to Ms. Rebecca Hermes et aI., dated June 17, 2011, in this matter.

I declare under penalty of perjury that the foregoing is true and correct and that this
declaration was executed on June 20, 2011, in Dallas, Texas.

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