`
`MICHELLE L. MARRIOTT (pro hac vice)
`michelle.marriott@eriseip.com
`ERIC A. BURESH (pro hac vice)
`eric.buresh@eriseip.com
`MARK C. LANG (pro hac vice)
`mark.lang@eriseip.com
`CHRIS R. SCHMIDT (SBN 298761)
` chris.schmidt@eriseip.com
`ERISE IP, P.A.
`7015 College Blvd, Suite 700
`Overland Park, Kansas 66211
`Telephone: 913.777.5600
`Facsimile: 913.777.5601
`
`Stephen S. Smith
`Law Offices of Stephen S. Smith, P.C.
`303 North Glenoaks Blvd., Suite 200
`Burbank, CA 91502
`Phone: (310)955-5824
`
`Attorneys for Ubisoft, Inc.
`
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`SOUTHERN DIVISION
`
`
`UNILOC 2017 LLC,
`Plaintiff,
`
`v.
`INFOR, Inc.,
`
`Defendant.
`________________________________
`UBISOFT, INC.
`
`Plaintiff,
`
`v.
`UNILOC 2017, LLC,
`Defendant.
`
`
`CASE NO. 8:19-cv-01150-DOC-KES
`(CONSOLIDATED)
`
`DECLARATION OF MICHELLE L.
`MARRIOTT IN SUPPORT OF
`UBISOFT, INC.’S MOTION FOR
`JUDGMENT ON THE PLEADINGS
`
`Judge: Hon. David O. Carter
`Date Filed: November 23, 2020
`Hearing Date: December 21, 2020
`Time: 8:30 AM
`Location: Ronald Reagan Federal
` Building, Courtroom 9D
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`DECLARATION OF MICHELLE L. MARRIOTT IN SUPPORT OF UBISOFT’S MOTION FOR
`JUDGMENT ON THE PLEADINGS
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`Case 8:19-cv-01150-DOC-KES Document 67-2 Filed 11/23/20 Page 2 of 3 Page ID #:1109
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`I, Michelle L. Marriott, declare as follows:
`I am an attorney license to practice law in the State of Kansas, admitted pro
`1.
`hac vice to practice in this Court, and am an attorney at the law firm of Erise IP, P.A.,
`counsel of record for Ubisoft, Inc., the Plaintiff and Counter-Defendant in the above-
`captioned lawsuit.
`I make this declaration on the basis of personal knowledge, except where
`2.
`indicated otherwise.
`Attached hereto as Exhibit A is a true and correct copy of Uniloc’s
`3.
`infringement contentions for U.S. Patent No. 7,069,293 served on Ubisoft on October
`29, 2019.
`Attached hereto as Exhibit B is a true and correct copy of Uniloc’s
`4.
`infringement contentions for U.S. Patent No. 6,324,578 served on Ubsioft on October
`29, 2019.
`Attached hereto as Exhibit C is a true and correct copy of Akamai
`5.
`Technologies, Inc.’s Memorandum in support of Motion for Judgment on the Pleadings
`filed on October 18, 2019 in Uniloc 2017 LLC v. Akamai Techs., Inc., No. 1:19-cv-
`11276-RGS, ECF No. 28 (D. Mass. Oct. 18, 2019).
`Attached hereto as Exhibit D is a true and correct copy of Uniloc’s
`6.
`Complaint filed against Akamai Technologies, Inc. on June 7, 2019 in Uniloc 2017 LLC
`v. Akamai Techs., Inc., No. 1:19-cv-11276-RGS, ECF No. 1 (D. Mass. June 7, 2019).
`Attached hereto as Exhibit E is a true and correct copy of Akamai
`7.
`Technologies, Inc.’s Reply in support of Motion for Judgment on the Pleadings filed on
`November 12, 2019 in Uniloc 2017 LLC v. Akamai Techs., Inc., No. 1:19-cv-11276-
`RGS, ECF No. 37 (D. Mass. Nov. 12, 2019).
`Attached hereto as Exhibit F is a true and correct copy of the Joint
`8.
`Stipulation to Stay Deadlines Pending the Court’s Decision on Akamai’s Motion for
`Judgment on the Pleadings filed on December 5, 2019 in Uniloc 2017 LLC v. Akamai
`Techs., Inc., No. 1:19-cv-11276-RGS, ECF No. 42 (D. Mass. Dec. 5, 2019).
`
`2
`DECLARATION OF MICHELLE L. MARRIOTT IN SUPPORT OF UBISOFT’S MOTION FOR
`JUDGMENT ON THE PLEADINGS
`
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`Case 8:19-cv-01150-DOC-KES Document 67-2 Filed 11/23/20 Page 3 of 3 Page ID #:1110
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`Attached hereto as Exhibit G is a true and correct copy of the Court’s
`9.
`December 12, 2019 order dismissing Uniloc’s case against Akamai Technologies, Inc.
`with prejudice in Uniloc 2017 LLC v. Akamai Techs., Inc., No. 1:19-cv-11276-RGS,
`ECF No. 44 (D. Mass. Dec. 12, 2019).
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed on November 23, 2020.
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`/s/ Michelle L. Marriott
`Michelle L. Marriott
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`DECLARATION OF MICHELLE L. MARRIOTT IN SUPPORT OF UBISOFT’S MOTION FOR
`JUDGMENT ON THE PLEADINGS
`
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