`#:59475
`
`
`
`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`James R. Asperger (Bar No. 83188)
`jimasperger@quinnemanuel.com
`Rachael McCracken
`rachaelmccracken@quinnemanuel.com
`865 South Figueroa Street, 10th Floor
`Los Angeles, CA 90017-2543
`Telephone: (213) 443-3000
`Facsimile: (213) 443-3100
`
`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`Kevin P.B. Johnson (Bar No. 177129)
`kevinjohnson@quinnemanuel.com
`Todd M. Briggs (Bar No. 209282)
`toddbriggs@quinnemanuel.com
`Brice C. Lynch (Bar No. 288567)
`bricelynch@quinnemanuel.com
`555 Twin Dolphin Drive, 5th Floor
`Redwood Shores, California 94065
`Telephone: (650) 801-5000
`Facsimile: (650) 801-5100
`
`QUINN EMANUEL URQUHART
` & SULLIVAN, LLP
`Eric Huang (pro hac vice)
`erichuang@quinnemanuel.com
`51 Madison Avenue, 22nd Floor
`New York, New York 10010
`Telephone: (212) 849-7000
`Facsimile: (212) 849-7100
`
`Attorneys for Plaintiffs
`NANTWORKS, LLC and NANT HOLDINGS IP, LLC
`
`
`
`
`UNITED STATES DISTRICT COURT
`
`FOR THE CENTRAL DISTRICT OF CALIFORNIA
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Case No. 2:20-cv-7872-GW-PVC
`DECLARATION OF BRICE C. LYNCH REGARDING PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO STRIKE
`PORTIONS OF THE REBUTTAL EXPERT REPORT OF DR. JAMES STORER
`
`
` CASE NO. 2:20-cv-7872-GW-PVC
`
`DECLARATION OF
`BRICE C. LYNCH REGARDING
`PLAINTIFFS’ REPLY IN SUPPORT
`OF MOTION TO STRIKE
`PORTIONS OF THE REBUTTAL
`EXPERT REPORT OF DR. JAMES
`STORER
`
`NANTWORKS, LLC, a Delaware
`limited liability company, and NANT
`HOLDINGS IP, LLC, a Delaware
`limited liability company,
`
`
`Plaintiffs,
`
`
`BANK OF AMERICA
`CORPORATION, a Delaware
`corporation, and BANK OF
`AMERICA, N.A., a national banking
`association,
`
`
`vs.
`
`Defendants.
`
`
`
`Case 2:20-cv-07872-GW-PVC Document 469-1 Filed 05/23/24 Page 2 of 3 Page ID
`
`#:59476
`
`
`
`
`
`I, Brice C. Lynch, declare as follows:
`
`1.
`
`I am an attorney duly licensed to practice law in the State of California
`
`and admitted before this Court. I am an attorney at Quinn Emanuel Urquhart &
`
`Sullivan, LLP, counsel for Plaintiffs NantWorks LLC and Nant Holding IP, LLC
`
`(“NantWorks”). I have personal knowledge of the facts set forth in this declaration,
`
`and if called as a witness I would testify competently to those facts.
`
`
`
`2.
`
`Exhibit A is a true and correct excerpted copy of Exhibit 1 of March 18,
`
`2022 Plaintiffs’ Revised Infringement Contentions titled, “Infringement of U.S.
`Patent 9,031,278 (the “’278 Patent”) by the Bank of America Accused Products”
`which has been designated “Highly Confidential - Attorney Eyes Only.”
`
`
`
`3.
`
`Exhibit B is a true and correct excerpted copy of Exhibit 2 of March 18,
`
`2022 Plaintiffs’ Revised Infringement Contentions titled, “Infringement of U.S.
`Patent 7,881,529 (the “’529 Patent”) by the Bank of America Accused Products”
`which has been designated “Highly Confidential - Attorney Eyes Only.”
`
`
`
`4.
`
`Exhibit C is a true and correct excerpted copy of Exhibit 3 of March 18,
`
`2022 Plaintiffs’ Revised Infringement Contentions titled, “Infringement of U.S.
`Patent 7,899,252 (the “’252 Patent”) by the Bank of America Accused Products”
`which has been designated “Highly Confidential - Attorney Eyes Only.”
`
`
`
`5.
`
`Exhibit D is a true and correct excerpted copy of Exhibit 5 of March 18,
`
`2022 Plaintiffs’ Revised Infringement Contentions titled, “Infringement of U.S.
`Patent 9,324,004 (the “’004 Patent”) by the Bank of America Accused Products”
`which has been designated “Highly Confidential - Attorney Eyes Only.”
`
`
`
`6.
`
`Exhibit E is a true and correct excerpted copy of Plaintiffs’ Corrected
`
`Third Supplemental Objections and Responses to Defendants Bank of America
`
`Corporation and Bank of America, N.A.’s Third Set of Interrogatories (Nos. 10-25)
`
`dated February 29, 2024. This document was designated as “Highly Confidential –
`
`Attorney’s Eyes Only.”
`
`
`
`
`
`
`
`
`-1-
`Case No. 2:20-cv-7872-GW-PVC
`DECLARATION OF BRICE C. LYNCH REGARDING PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO STRIKE
`PORTIONS OF THE REBUTTAL EXPERT REPORT OF DR. JAMES STORER
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`
`
`
`
`Case 2:20-cv-07872-GW-PVC Document 469-1 Filed 05/23/24 Page 3 of 3 Page ID
`
`#:59477
`
`
`
`I declare under penalty of perjury under the laws of the United States of
`
`America and the State of California that the foregoing is true and correct, and that this
`
`declaration was executed in Walnut Creek, California, on May 23, 2024.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`By
`/s/ Brice C. Lynch
`Brice C. Lynch
`
`
`
`-2-
`Case No. 2:20-cv-7872-GW-PVC
`DECLARATION OF BRICE C. LYNCH REGARDING PLAINTIFFS’ REPLY IN SUPPORT OF MOTION TO STRIKE
`PORTIONS OF THE REBUTTAL EXPERT REPORT OF DR. JAMES STORER
`
`1 2 3 4 5 6 7 8 9
`
`10
`
`11
`
`12
`
`13
`
`14
`
`15
`
`16
`
`17
`
`18
`
`19
`
`20
`
`21
`
`22
`
`23
`
`24
`
`25
`
`26
`
`27
`
`28
`
`
`
`