Microsoft Corporation v. Immersion Corporation

Filing 66

DECLARATION of Alan J. Heinrich filed by Defendant Immersion Corporation re 56 MOTION to Compel Production of Documents Responsive to Request Nos. 53, 54 and 71 and Referenced in Response to Interrogatory No. 7 (Attachments: # 1 Exhibit 1# 2 Exhibit 2)(Kaplan, David)

Microsoft Corporation v. Immersion Corporation

Doc. 66

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The Honorable Ricardo S. Martinez

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON MICROSOFT CORPORATION, a Washington ) corporation, ) ) Plaintiff, ) ) v. ) ) IMMERSION CORPORATION, a Delaware ) corporation, ) ) Defendant. ) ) ) ) ) ) I, Alan J. Heinrich, declare as follows: 1. I am a partner at the law firm of Irell & Manella LLP, co-counsel of record for

No. CV07 936RSM DECLARATION OF ALAN J. HEINRICH IN SUPPORT OF IMMERSION'S REPLY IN SUPPORT OF ITS MOTION TO COMPEL RESPONSES TO REQUEST FOR PRODUCTION NOS. 53, 54 AND 71 AND REFERENCED IN RESPONSE TO INTERROGATORY NO. 7 NOTED ON MOTION CALENDAR: March 28, 2008

defendant Immersion Corporation ("Immersion") in the above captioned action. I am a member in good standing of the California State Bar and am admitted to practice before this Court in this case pro hac vice. I have personal knowledge of the facts set forth in this Declaration and, if called as a witness, could and would testify competently to such facts under oath. 2. Attached hereto as Exhibit 1 is a true and correct copy of excerpts from the

unofficial deposition transcript of Patrick Reutens, which deposition was taken on March 24, 2008. I have not yet received the official deposition transcript for Mr. Reuten's deposition.

IRELL & MANELLA LLP
A Registered Limited Liability Law Partnership Including Professional Corporations

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DECLARATION OF ALAN J. HEINRICH IN SUPPORT OF IMMERSION'S REPLY IN SUPPORT OF ITS MOTION TO COMPEL PRODUCTION OF DOCUMENTS (CV07 936RSM)

Dockets.Justia.com

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3.

Attached hereto as Exhibit 2 is a true and correct copy of excerpts from the

deposition transcript of Jennifer Liu, which deposition was taken on December 20, 2007. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed on March 28, 2008, at Los Angeles, California. By /s/ Alan J. Heinrich Alan J. Heinrich

IRELL & MANELLA LLP
A Registered Limited Liability Law Partnership Including Professional Corporations

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DECLARATION OF ALAN J. HEINRICH IN SUPPORT OF IMMERSION'S REPLY IN SUPPORT OF ITS MOTION TO COMPEL PRODUCTION OF DOCUMENTS (CV07 936RSM)

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CERTIFICATE OF SERVICE The undersigned attorney certifies that on the 28th day of March, 2008, I electronically filed the foregoing with the Clerk of the Court using the CM/ECF system which will send notification of such filing to the following: Paul J. Kundtz ([e-mail]) Blake Marks-Dias ([e-mail]) Wendy E. Lyon ([e-mail]) Riddell Williams P.S. 1001 Fourth Avenue Plaza, Suite 4500 Seattle, WA 98154-3600 Attorneys for Plaintiff /s/ David R. Kaplan David R. Kaplan Irell & Manella LLP 1800 Avenue of the Starts, Suite 900 Los Angeles, CA 90067-4276 Telephone: [phone] Facsimile: [phone] Byrnes & Keller LLP 1000 Second Avenue, 38th Floor Seattle, WA 98104 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant Immersion Corporation

IRELL & MANELLA LLP
A Registered Limited Liability Law Partnership Including Professional Corporations

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DECLARATION OF ALAN J. HEINRICH IN SUPPORT OF IMMERSION'S REPLY IN SUPPORT OF ITS MOTION TO COMPEL PRODUCTION OF DOCUMENTS (CV07 936RSM)