`Case 2:17-cv-04263-JVS-JCG Document 29 Filed 09/06/17 Page 1 of 2 Page ID #:294
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`Jacqueline K. S. Lee
`JONES DAY
`1755 Embarcadero Road
`Palo Alto, CA 94303
`Telephone: 650.739.3939
`Facsimile: 650.739.3900
`jkslee@jonesday.com
`
`Blaney Harper
`JONES DAY
`51 Louisiana Avenue, N.W.
`Washington, DC 20001-2113
`Telephone: 202.879.3939
`Facsimile: 202.626.1700
`bharper@jonesday.com
`Attorneys for Defendant Cree, Inc.
`UNITED STATES DISTRICT COURT
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`Document Security Systems, Inc.,
`Case No. 2:17-cv-04263-JVS-JCG
`DECLARATION OF YURY
`Plaintiff,
`KALISH IN SUPPORT OF
`DEFENDANT CREE, INC.’S
`MOTION TO TRANSFER
`VENUE PURSUANT TO 28
`U.S.C. § 1404(a)
`
`v.
`Cree, Inc.,
`
`Defendant.
`I, Yury Kalish, declare as follows:
`I am a lawyer in the law firm of Jones Day, counsel of record for
`Defendant Cree, Inc. (“Cree”). I have personal knowledge of the facts set forth
`herein and, if called and sworn as a witness, could and would competently testify
`thereto. I submit this declaration in support of Defendant Cree, Inc.’s Motion to
`Transfer Venue Pursuant to 28 U.S.C. § 1404(a).
`Attached hereto as Exhibit 1 is a true and correct copy of the
`1.
`assignment records maintained at the USPTO for U.S. Pat. Nos. 6,949,771 (“the
`’771 patent”); 7,256,486 (“the ’486 patent”); 7,524,087 (“the ’087 patent”) and
`7,919,787 (“the ’787 patent”).
`Attached hereto as Exhibit 2 is a true and correct copy of the
`2.
`recorded inventors’ declaration from the file history of the ’771 patent.
`DECLARATION OF YURY KALISH IN SUPPORT OF
`
`Case No. 2:17-cv-04263-JVS-JCG
`DEFENDANT’S MOTION TO TRANSFER
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`
`
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`Case 2:17-cv-04263-JVS-JCG Document 29 Filed 09/06/17 Page 2 of 2 Page ID #:295
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`Attached hereto as Exhibit 3 is a true and correct copy of the
`3.
`recorded inventors’ declaration from the file history of the ’486 patent.
`Attached hereto as Exhibit 4 is a true and correct copy of the
`4.
`recorded inventors’ declaration from the file history of the ’087 patent.
`Attached hereto as Exhibit 5 is a true and correct copy of the
`5.
`recorded inventors’ declaration from the file history of the ’787 patent.
`Attached hereto as Exhibit 6 is a true and correct copy of the
`6.
`“Corporate Overview” presentation maintained (as of August 9, 2017) on the
`Document Security Systems, Inc. (“DSS”) website (http://www.dsssecure.com/)
`under the “Investors” heading.
`Attached hereto as Exhibit 7 is the DSS Form 10-K filed with the
`7.
`Securities and Exchange Commission (“SEC”), dated March 28, 2017, and
`maintained on the DSS website as of at least August 9, 2017.
`Attached hereto as Exhibit 8 is the original DSS complaint against
`8.
`Cree filed in the Eastern District of Texas, numbered 2:17-CV-00309.
`I declare under penalty of perjury under the laws of the United States of
`America that the facts stated in this declaration are true and correct.
`Executed on August 28th, 2017, at Washington, D.C.
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`By: /s/ Yury Kalish
`Yury Kalish
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`DECLARATION OF YURY KALISH IN SUPPORT OF
`DEFENDANT’S MOTION TO TRANSFER
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`2
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`Case No. 2:17-cv-04263-JVS-JCG
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