Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 906

MOTION to Strike Defendant's Daubert Motion to Preclude Expert Testimony of Jonathan H. Bari by Adobe Systems Incorporated, Amazon.com Inc., Citigroup Inc., Google Inc., J.C. Penney Company, Inc., Staples, Inc., The Go Daddy Group, Inc., Yahoo! Inc., YouTube, LLC. (Attachments: # 1 Affidavit of Aaron Huang, # 2 Exhibit A to Huang Decl, # 3 Exhibit B to Huang Decl, # 4 Text of Proposed Order)(Reines, Edward)

UNITED STATES DISTRICT COURT
EASTERN DISTRICT OF TEXAS
TYLER DIVISION

EOLAS TECHNOLOGIES
INCORPORATED,
PLAINTIFF,
v.
ADOBE SYSTEMS INC. et al.,
DEFENDANTS.

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Civil Action No. 6:09-CV-446-LED

JURY TRIAL DEMANDED

DECLARATION OF AARON Y. HUANG IN SUPPORT OF DEFENDANTS’ DAUBERT
MOTION TO EXCLUDE EXPERT TESTIMONY OF JONATHAN H. BARI
I, Aaron Y. Huang, hereby declare:
1.

I am an attorney with the law firm of Weil, Gotshal & Manges LLP, counsel of

record for Yahoo! Inc. (“Yahoo”) and Amazon.com, Inc. (“Amazon”) (collectively,
“Defendants”) in the above-captioned matter.

I submit this declaration based on personal

knowledge following a reasonable investigation. If called upon as a witness, I could competently
testify to the truth of each statement herein.
2.

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

from counsel for Plaintiff Eolas Technologies, Inc., titled Expert Report of Jonathan H. Bari, and
dated July 25, 2011.
3.

Attached hereto as Exhibit B is a true and correct copy of the Order Granting

Defendants’ Motion to Exclude Certain Testimony of Fractus’ Survey Expert Witnesses, Docket

Number 896 in Fractus, S.A. v. Samsung et al., Case 6:09-cv-00203-LED-JDL, filed April 29,
2011.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct.
Executed:

August 19, 2011

__/s/ Aaron Y. Huang____________________
Aaron Y. Huang
Attorney for Defendants Yahoo!, Inc. and
Amazon.com, Inc.

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