Case 5:15-cv-02008-EJD Document 83-6 Filed 04/12/16 Page 1 of 4
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`EXHIBIT 6
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`DECLARATION OF MELODY DRUMMOND HANSEN IN SUPPORT OF DEFENDANT’S
`RESPONSIVE CLAIM CONSTRUCTION BRIEF
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`Case No. 5:15-CV-02008-EJD
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`Case 5:15-cv-02008-EJD Document 83-6 Filed 04/12/16 Page 2 of 4
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`COPYRIGHT © 1990 BY LEXICON PUBLICATIONS, INC.
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`Main dictionary section © 1972 Librairie Larousse as The Larousse Illustrated International
`Encyclopedia and Dictionary. Revised and updated 1990.
`
`All rights reserved. l./o purl of this book rnuy be reproduced or transrnitted in any fonn by
`any 1neanselec1ronic, mechanical, or otherwise, whether now or hereafter devised, including
`photocopying, recording. or by any information storage and retrieval system without express
`written prior permission from the Publisher.
`
`We have reason to believe that a nurnber of words entered ;n this dictionary constitute
`trademarks, and we have designated the1n as such. However, neither the presence nor the
`absence of such designation should be regarded as affecting the legal Jf(lfvs of nny
`trademark.
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`PRINTED AND MANUE.l.CTURED JN THE UNJTED STATES OF AMERICA
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`ISBN 0-7172-4576-4
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`Case 5:15-cv-02008-EJD Document 83-6 Filed 04/12/16 Page 4 of 4
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`India ink
`80" in the :south, (11ay) 80° in the northeast, 85°
`along the west coast and Ganges delta, 90° in
`the south, east and north, 95° in the center.
`Rainfall: 426 ins on the Shillong plateau, 75-
`150 ins along the Malabar coast, the lower
`slopes oft.he Himalayas and the lower Brahma(cid:173)
`putra, over 60 ins along the Himalayas and
`lower Ganges, 50 ins in Mndro.s, 45 ins in Visn(cid:173)
`khapatnam, over 30 ins in the river valleys of
`N. India, 15-30 ins along the S. Coromandel
`cotist; in the P1_1njab, in Delhi; Agr;_:i anil the
`interior of S. India, under 10 ins in the Thar.
`Livestock: cattle;.. v.·atcr buffo.k:cs, gouts, sheep,
`poultry, horses. Grops: cereals, rice, sugarcane,
`jute, cotton, pe!'lnuts, rape and mustard, to(cid:173)
`bacco, spices, vegetables, fruit, tea, coffee, rub·
`ber, opium, wool. Woods: teak, sal, deodar.
`Minerals: coal, manganese ore, petroleum (As·
`sam), iron ore, mica, copper, ilmenite, gypsum,
`bauxite, chromite, marble, sandstone, granite.
`Industries: cotton, jute and silk textiles, engi·
`neering, iron and steel, sugar, chemicals, pvt·
`tery, shipbuilding, hydroelectricity. Exports:
`tea, jute, cotton, leather, iron ore, j'eanuts,
`manganese ore, mica, coffee, sugar. mports:
`machinery, wheat, cotton, oil, vehicles, chemi(cid:173)
`cals, rice, metals. Main ports: Bombay, Cal(cid:173)
`cutta, Madras, Cochin, Visakhapatnam. There
`are 62 universities, the three oldest being Cal·
`cutta, Bombay and Madras. Monetary unit:
`Indian rupee (100 paise). HISTORY. The earliest
`known Indian civilization is that of the Indus
`vaiiey (c. third miHennium B.CJ, centered on
`Mohenjo-Daro and Harappa. The Aryans in(cid:173)
`vaded the Punjab (c. 1500 B.C.) and spread
`through N. India to Bengal {c. 800 RC.), displac(cid:173)
`ing the Dravidian inhabitants. The Aryan reli(cid:173)
`gion, based on the Vedas, became incorporated
`in Brahmanism (c. 1000 B.C.), Jainism and Bud(cid:173)
`dhism (6th c. s. c.). Alexander the Great
`invaded the Punjab (327 B.C.), but the Greeks
`were driven out by Chandragupta, the founder
`of the Maur:va Empire (325-184 B.C.). Hindu(cid:173)
`ism was the State re1igion until the reign (c. 273
`B.C.-c. 23'2. B.C.) of Asoka, who replaced it by
`Buddhism. On his death, the Maurya Empire,
`which now included most oft.he subcontinent,
`began to disintegrate. N. India "''as invaded and
`ruled by the Greeks (2nd c. B.C.), and the Par(cid:173)
`thians (1st c. B.C.-lst c. A.D.). The Gupta
`dynasty (c. 320-c. 544) created a new empire in
`N. India, but failed to gain control of the south.
`Hindu art. and culture reached their zenith in
`t.liis period. The Hun invasion (6th -.:.) and the
`~~.tj;]f~\~.et~ag~~~fi~.!~~i!:jf~i:. fr.~a:.~.h~
`west by Turks and Persians (1{101-26) under
`t'1ahmud of Ghazni. The Delhi sultanate
`(1206-1526) conquered most of the Hindu
`states except Kashmir, but was weakened
`when Timur captured Delhi (1398). It was re~
`placed in the north by separate Moslem king(cid:173)
`doms, which were subdued {1526) by Babur, the
`founder of the ~fogul Empire (1526-1707).
`Du.ring the H:lgn (1556-1605) of Akbar, r~1ugul
`power was extended to nmst of northern and
`centrai India and the administration of the em(cid:173)
`pire was reformed. Mogul architecture reached
`its height under the rule (1627-58) of Shah
`Jahan, but the empire began to disintegrate
`aft.er the reign {1658-1707) of Aurangzeb.
`European interest in India began with Vasco
`da Gama's arrival (1498) at Calicut. The
`British East India Company estab1ished trad(cid:173)
`ipg posts at Surat (1612), Bombay (1661) and
`Calcutta (1690), driving off Portuguese and
`Dutch opposition. With the decline of the Mogul
`emyire, and the emergence of the Marathas, the
`Bntish and French tried to extend their influ(cid:173)
`ence over the native states (18th c.). The P.USll·
`ing Anglo· French conflict (1746-63) resulted in
`the expulsion of the French by the military vie·
`tories of Clive. The British raj was extended by
`Warren Hastings, and by 1850 covered the
`whole of India. After the Indian I\olutiny (1857),
`the control of India na.c:sP.rl to thP. Rrit.ish r-rnwn
`(1858) and <\ueen ViCtOri.i ·beC8.me effipress Or
`India (1877). ~ndian desire for sclf-govcrr ... T.cnt
`led to the formation of the Indian National Con·
`gress (1885) and the Moslem League (1906}.
`After the lst world war, the G-Overnment of
`India Act (1919) failed t-0 transfer realfowerto
`elected officials. Gandhi led a policy o passive
`resistance to British rule. Provincial legisla(cid:173)
`tures were set up by the Government of India
`Act (1935), but the rift between Hindus and
`~.1oslems continued to widen. A mission (1D42)
`led by Sir Stafford Cripps failed to unify Indian
`
`492
`leaden; on a formula for a transfer of power, and
`a.t ~he end of the 2nd world war a polky ofp;_n.
`tition was agreed on. On Aug. 15, 194 7, the
`country was partitioned to form the two new
`states of India and Pakistan. The princely
`state.<; (more than 500 in number) which had
`political agreements with British India, were
`allowed to join either India or Pakistan. The
`partition was marked by great bloodshed and
`there was a hu!f,e refugee problem. Hyderabad,
`~~~4~r~~~ti~:l!fr~i~~~\~;\~t~;de~~~i~hr~~h
`India and Pakistan, presented a problem. In the
`end the maharaja opted to join India, but Paki(cid:173)
`stan contested the decision and a bitter di~ute
`followed, leading to U.N. intervention. Kash·
`mir was formally admitted to the Indian Union
`(1957), but parts of its western mountainous
`regions continued to be controlled Ly Paki(cid:173)
`stan.
`Under the constitution of the Republic of
`India (Jan. 26, 1950), India is a union of states,
`each with its own governor and legislative as(cid:173)
`sembly. The Congress party under Nehru ere.
`ated (1949-56) a strong central government.
`By 1956, the former French territories had been
`incorporated in the reJ?ublic. The Portuguese
`possession of Gua was uivaded (1961) and an·
`nexed (1962). Overpopulation and frontier dis(cid:173)
`putes with China on
`the northwest and
`northeast borders have strained India's econ(cid:173)
`omy. '!',!le .Jong·s~an~ing dispute with Pakistan
`over Kashmir broke bnetty into open war
`(1965). Shortly after sil!D.ing an agreement at
`Tashkent with Pakistarl to rest-0re llormal rela(cid:173)
`tions between the two countries, Shastri, the
`prime minister, died, and was succeeded by In(cid:173)
`dira Gandhi in 1966. Her first 11 years in office
`saw many improvements in agriculture, irriga(cid:173)
`tion, and P.Ower production~ sources of natural
`gas and ml were discovereo; and many indus(cid:173)
`tries were nationalized. In 1974, India entered
`the nuclear age with the explosion of its first
`nuclear device. India helped establish Bangla(cid:173)
`desh as an :independent state in 1971, und in
`1975 Sikkim became an Indian state. Economic
`and social problems continued, however, and
`mounting political opposition along with a rash
`of strikes and riots persuaded Gandhi to declare
`a state of emergency in 1975, during which
`time many political opponents were jailed and
`constitutional rights suspended. In ~larch 1977
`~:reeheY!G~ii'd}ria;e;t~:d ~1a~~~e~f ~~c;~~~
`sition coalition. This coalition did not hold
`together, however, and Gandhi returned to of~
`fice in a caretaker government; she was reelec·
`ted in 1980. Sikh opposition forces becan1e
`violently active in the early 1980s and in Octo(cid:173)
`ber 1984 Gandhi was assassinated by Sikh
`security guards. She was succeeded by her son
`Rajiv Gandhi, who won an overwhelming vic·
`tory later that year, but opposition to his
`government grew in the late 1980s. Settle·
`inents in the -Punjab and Assam (1985), and
`with Sri Lanka (1987) were negotiated. How~
`ever, clue to continued violence, some civil
`liberties were suspended in the Punjab (1988)
`India ink (A1n.~Br. Indian ink) a black pig·
`ment, consisting of lampblack mixed with a
`binder, used in painting, lettering etc. !I the liq(cid:173)
`uid ink made from this pigment
`In.W•an (indi:an) 1. n. a citizen of the republic of
`India II one of the original inhabitants of Amer(cid:173)
`ica Ii any of the A..11erican. Indian. lang-uages 2,
`adj. of or pertaining to the subcontinent or the
`repubiic of India !i of or pertaining to the citi·
`zens of the republic of India, or to their culture
`etc. [I of or pertaining to the original inhabitants
`of America, their languages, culture etc.
`(*LATIN AMERICAN INDIANS, -*NORTH AMERICAN
`INDIANS)
`ln·di·an•a (indi:<ena) (abbr. Ind.) a state (area
`36,291 sq. miles, pop, 5,479,000) on midwestern
`plains of the U.S.A. Capital: Indianapolis. Agri·
`culture (80% is farmed): corn and otlier cere8ls,
`tornatoes, soybeans, fnigs. Resources: coal,
`building limestone, oi . Industries: iron and
`steel, motor vehicles, aircraft and rail equip·
`ment, oil refining, machinery. Chief universi(cid:173)
`ties: Indiana University (1824) at Bloomington,
`Purdue (1869) at Lafayette and Notre Dame
`(1842) at South Bend. Indiana was settled (18th
`c.) by French fur traders, was cede<l (1763) to
`Britain, and with the Revolution passed (1779)
`under t..11.e control of tI1e U.S.A., of which it
`became (1816) the 19th state
`
`indication
`Indian Affairs, Bureau of (BIA), U.S. federal
`al!encv th::it. h::ind!P.s Tnrli:m m;it.t.Pr.<: !';llf'h ''"''
`educahon, mineral and water rights:1ana·1ea~:
`ing, Socia.I services, law enforcement and job
`training on Indian reservations. Originally a
`part. of the War Department from 1824, it
`became part of the Department of the Interior
`in 1849 and is directed by the department's
`assistant secretary of Indian affairs
`ln•di•an•ap•o•lis (jndi:ani:palis)
`the
`car,ital
`~Pn°f.· c~~~8~0o~ ti:!t~0~g~~}g1a~~t3i~~alft;~g~-
`meat packing, metallurgy, pharmaceuticals
`'
`Indian club a bottle·shaped wood or metal club
`used in exercises to strengthen the muscles
`'
`Indian corn *CORN {maize)
`Indian Desert *THAR
`Indian file single file [after the American In(cid:173)
`dian way of moving along trail:s1
`Indian giver (pop.) a person who gives a
`present and then asks for it back
`Indian hemp ~pucynum. u.t.nn.abihurn, fam.
`Ap~9·nrn:.~ae, ~ Nort~ Americap dog~ane fr_om
`wn1cn a noer tor cord.age was tormer!y made II
`hemp 11 sunn hemp
`Indian ink (Br.) India ink
`in•dia•nis•mo (i:ndjoni:sm::i) n. a cultural move·
`ment in Latin A1nerica, esp. (and originally) in
`11exico, which draws national pride from na(cid:173)
`tive folklore and the native race. In Mexico it
`owes much to Emiliano Zapata and to the mu(cid:173)
`ral painters Diego Rivera, Jose Clemente
`Orozco, and David Alfaro 8iquP.itos [Span.J
`Indian meal cornmeal
`Indian millet durra
`Indian Mutiny a rebellion (1857-8) of the Ben·
`gal Sepoys against British rule in India. It was
`largely caused by Hindu opposition to British
`attempts to impose social reforms. The revolt
`spread quickly through central India, causing
`much bloodshed, and was repressed with great
`severity. It resulted in the Government. oflnclia
`Act (1858), by which the rule of India pa~<;P.d
`from the East India Company to the Crown
`Indian N~ticr...U Ccngrcss a politkal or5..ni(cid:173)
`zation founded in 1885 in India lo prurnote
`constitutional progress. Under Gandhi and
`Nehru it campaigned for independence after
`the 1st world war. Aft.er 1947 the Congress
`party remained dominant in India
`ln•di•an•ness (indi:gnnjs) n: the quality afbeing
`Indian (Native American or Eastern)
`Indian Ocean the ocean (area incl. seas, gulfs
`and Antarctic waters, 29,000,000 :sq. n1ile:s) Lto(cid:173)
`tween Africa, Asia, and Australia. Length (Pa(cid:173)
`kistan-Antarctica): 6,000 miles. Width (South
`Africa to Australia): 6,500 miles. The Great
`Indian Ridge (the Maldive Is and 1fauritius are
`summits) running to Antarctica divides it into
`an eastern valley, relatively unaccidented, and
`a western valley broken by smaller ridges cul(cid:173)
`minating in many islands. Average valley
`depth: 2,700 fathoms. Deeps reach 4,100 fath(cid:173)
`oms (Sundas trench). The monsoons. chancing
`direction with the seasons, reverse itS currintS:
`Oct.-Apr. generally north, May-Sept. south
`and west
`Indians, North American *NORTH AMERICAN
`INDIANS
`Indian summer a period of warm, dry _weather
`in late autumn, esp. in North America
`Indian Territory country set aside under the
`Indian Intercourse Act (1834) for Indians ii the
`eastern part of present Oklahoma, where Indi(cid:173)
`ans were gradually forced to settle
`India paper a ve_ry thin, soft; but strong paper
`originally made in China and J"apan, used for
`making prints of engravings II a thin, tough
`printing paper, used esp. for Bibles, prayer
`books etc.
`india rubber natural rubber Ii a n.1bber eraser
`lndic *INDIC LANGUAGES
`indie. indicative
`in-di•can (indikan) n. a natural glucoside found
`in plants of genus lndigvfera. the decornuo:si(cid:173)
`tioii of whicli makes iiidlgo ·aye II a noT:mal
`constituent of u~.ne which yields intligo upon
`oxidation [fr. L. indicum, indigo)
`(fndikeit) pres. part. in·di·cat•ing
`in·di·cate
`past and past part. in•di-cat•ed · u.t. to direct
`attention to II to point out, show, a signpost indi·
`ca.tes the road II to denote the probability of, his
`symptoms indicate mumps II to state in brief,
`indicate what you think about this [fr. L. indi·
`care (indi.catus), to make known]
`in·di·ca-tinn qndik;§iJ;;n) n.. smnetl1ing that in·
`dicates 11 an indicating or being indicated (F.]
`
`i., sheep; ia, deer; ca, bear
`(i) 1, fl.Sh, a1, tiger, a·, bird
`(c) c, hen,
`CONCISE PRONUNCIATION KEY: (a) ae, cat; o, car, :'.>fawn; cl, snake.
`(o) o, ox; au, cow; ou, goat; u, poor; ::ii, royal.
`(u) A, duck, u, bull; u·, goose, a, bacillus; JU., cube
`x, loch; 8, th1nk, 0, bother, z, Zen, 3, corsage,
`d3, savage; JJ, orangutang; j, yak; f, fish; tf, fetch;
`'l, rabble; 'n, redden. Complete pronunciation key appears InSlde front cover
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