Apple, Inc. v. Motorola, Inc. et al

Filing 109

Declaration of Carlos A. Rodriguez filed by Defendants Motorola Mobility, Inc., Motorola, Inc. re: 95 Motion Requesting Claims Construction by Defendants. (Attachments: # 1 Exhibit 1 - Excerpts from Patent No. 6,275,983 Prosecution History, # 2 Exhibit 2 - Excerpts from Patent No. 6,212,575 Prosecution History, # 3 Exhibit 4 - July 4, 1011 Correspondence from Erwine to Haskett, # 4 Exhibit 5 - Excerpts from Patent No. 6,175,559 Prosecution History, # 5 Exhibit 6 - Excerpts from July 13, 2011 Deposition of Leonard Cimini, Ph.D., # 6 Exhibit 7 - Excerpts from American Heritage College Dictionary) (Hansen, Scott) Modified on 7/18/2011 (llj).

UNITED STATES DISTRICT COURT
FOR THE WESTERN DISTRICT OF WISCONSIN
APPLE INC. and NeXT SOFTWARE
INC. (f/k/a NeXT COMPUTER, INC.),
Plaintiffs,
v.
MOTOROLA, INC. and MOTOROLA
MOBILITY, INC.
Defendants.

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Case No. 10-cv-662-bbc
JURY TRIAL DEMANDED

DECLARATION OF CARLOS A. RODRIGUEZ IN SUPPORT OF
MOTOROLA'S RESPONSIVE CLAIM CONSTRUCTION BRIEF

I, Carlos A. Rodriguez, declare as follows:
1.

I am a member of the bar of the State of New York and am admitted to practice

pro hac vice before this Court. I am an associate with Quinn Emanuel Urquhart & Sullivan LLP,
attorneys for Defendants Motorola Solutions, Inc. and Motorola Mobility, Inc. ("Motorola"). I
make this declaration of personal, firsthand knowledge, and if called and sworn as a witness, I
could and would testify competently thereto.
2.

All exhibits attached hereto are cited in Motorola's Responsive Claim

Construction Brief.
3.

Exhibit 1 is a true and correct copy of excerpts of the prosecution history of U.S.

Patent No. 6,275,983.
4.

Exhibit 2 is a true and correct copy of excerpts of the prosecution history of U.S.

Patent No. 6,212,575.

5.

Exhibit 3 is a true and correct copy of excerpts from the transcript of the

deposition of Bertrand Serlet, taken on November 16, 2010, in the matter of Certain Personal
Data And Mobile Communications Devices And Related Software, USITC Inv. No. 337-TA-710.
6.

Exhibit 4 is a true and correct copy of e-mail correspondence sent on July 4, 2011

by Richard Erwine, counsel for Motorola, to Christine Haskett, counsel for Apple Inc. and NeXT
Software, Inc.
7.

Exhibit 5 is a true and correct copy of excerpts of the prosecution history of U.S.

Patent No. 6,175,559.
8.

Exhibit 6 is a true and correct copy of excerpts from the unedited, draft transcript

of the deposition of Leonard Cimini, Ph.D., taken on July 13, 2011.
9.

Exhibit 7 is a true and correct copy of pages from The American Heritage College

Dictionary (3d ed. 1993).

I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct. Executed July 15, 2011, at New York, New York.

/s/ Carlos A. Rodríguez

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