`
`Case 5:18-md-02834-BLF Document 864-1 Filed 04/08/23 Page 1 of 4
`
`
`
`J. DAVID HADDEN (CSB No. 176148)
`dhadden@fenwick.com
`SAINA S. SHAMILOV (CSB No. 215636)
`sshamilov@fenwick.com
`MELANIE L. MAYER (admitted pro hac vice)
`mmayer@fenwick.com
`TODD R. GREGORIAN (CSB No. 236096)
`tgregorian@fenwick.com
`RAVI R. RANGANATH (CSB No. 272981)
`rranganath@fenwick.com
`CHRISTOPHER S. LAVIN (CSB No. 301702)
`clavin@fenwick.com
`FENWICK & WEST LLP
`Silicon Valley Center
`801 California Street
`Mountain View, CA 94041
`Telephone:
`650.988.8500
`Facsimile:
`650.938.5200
`
`Counsel for AMAZON.COM, INC.,
`AMAZON WEB SERVICES INC., and
`TWITCH INTERACTIVE, INC.
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`IN RE: PERSONALWEB TECHNOLOGIES,
`LLC ET AL., PATENT LITIGATION,
`
`AMAZON.COM, INC., and AMAZON WEB
`SERVICES, INC.,
`Plaintiffs,
`
`v.
`PERSONALWEB TECHNOLOGIES, LLC and
`LEVEL 3 COMMUNICATIONS, LLC,
`Defendants.
`
`
`
`PERSONALWEB TECHNOLOGIES, LLC and
`LEVEL 3 COMMUNICATIONS, LLC,
`Plaintiffs,
`
`v.
`
`TWITCH INTERACTIVE, INC.,
`
`Defendant.
`
`DECL OF TODD R. GREGORIAN ISO AMAZON’S
`SUPPLEMENTAL SUBMISSION
`
`
`
`Case No.: 5:18-md-02834-BLF
`Case No.: 5:18-cv-00767-BLF
`Case No. 5:18-cv-05619-BLF
`DECLARATION OF TODD R.
`GREGORIAN IN SUPPORT OF
`AMAZON’S SUPPLEMENTAL
`SUBMISSION REGARDING
`AMAZON'S MOTION TO COMPEL
`PRODUCTION OF DOCUMENTS
`THAT THE PERSONALWEB
`INVESTORS HAVE IMPROPERLY
`WITHHELD AS PRIVILEGED
`
`
`
`
`
`
`
`CASE NOS.: 5:18-md-02834-BLF;
`5:18-cv-00767-BLF; 5:18-cv-05619-BLF
`
`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
`
`ATTORNEYS AT LAW
`
`FENWICK & WEST LLP
`
`
`
`
`

`

`Case 5:18-md-02834-BLF Document 864-1 Filed 04/08/23 Page 2 of 4
`
`
`
`I, Todd R. Gregorian, declare as follows:
`1.
`I am a partner at the law firm Fenwick & West, LLP, attorneys of record for
`Amazon.com, Inc., Amazon Web Services, Inc., and Twitch Interactive, Inc. (collectively
`“Amazon”). I make this declaration in support of Amazon’s Supplemental Submission Regarding
`Amazon’s Motion to Compel Production of Documents that the PersonalWeb Investors Have
`Improperly Withheld as Privileged.
`Attached as Exhibit 1 is a true and correct copy of an excerpt from the
`2.
`OPPOSITION TO THE SPECIAL MOTIONS TO STRIKE COMPLAINT AND MOTIONS TO
`STRIKE PORTIONS OF COMPLAINT BY AMAZON.COM, INC., AMAZON WEB
`SERVICES, INC., AND TWITCH INTERACTIVE, INC., filed April 4, 2023 in Superior Court,
`County of Los Angeles, Civ. A No. 21VECV00575.
`Attached as Exhibit 2 is a true and correct copy of the DECLARATION OF TODD
`3.
`GREGORIAN IN SUPPORT OF THE OPPOSITION TO THE SPECIAL MOTIONS TO STRIKE
`COMPLAINT AND MOTIONS TO STRIKE PORTIONS OF COMPLAINT BY
`AMAZON.COM, INC., AMAZON WEB SERVICES, INC., AND TWITCH INTERACTIVE,
`INC. AND SUPPORTING EXHIBITS, filed April 4, 2023 in Superior Court, County of
`Los Angeles, Civ. A No. 21VECV00575.
`Attached as Exhibit 3 is a true and correct copy of a document produced by Brilliant
`4.
`Digital Entertainment, Inc. (“BDE”) bearing Bates Nos. BDE-00064430 (designated as “Attorneys’
`Eyes Only”).
`Attached as Exhibit 4 is a true and correct copy of a document produced by BDE
`5.
`bearing Bates Nos. BDE-00064453-64454 (designated as “Attorneys’ Eyes Only”).
`Attached as Exhibit 5 is a true and correct copy of a document produced by Frandzel
`6.
`Robins Bloom & Csato L.C. (“FRBC”) bearing Bates Nos. FRBC-00002384-2385 (designated as
`“Confidential”).
`Attached as Exhibit 6 is a true and correct copy of a document produced by BDE
`7.
`bearing Bates Nos. BDE-000023095-23292 (designated as “Confidential”).
`
`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
`
`ATTORNEYS AT LAW
`
`FENWICK & WEST LLP
`
`
`
`DECL OF TODD R. GREGORIAN ISO AMAZON’S
`SUPPLEMENTAL SUBMISSION
`
`
`
`1
`
`CASE NOS.: 5:18-md-02834-BLF;
`5:18-cv-00767-BLF; 5:18-cv-05619-BLF
`
`

`

`Case 5:18-md-02834-BLF Document 864-1 Filed 04/08/23 Page 3 of 4
`
`
`
`Attached as Exhibit 7 is a true and correct copy of a document produced by BDE
`8.
`bearing Bates Nos. BDE-00023293-23312 (designated as “Confidential”).
`Attached as Exhibit 8 is a true and correct copy of a document produced by BDE
`9.
`bearing Bates Nos. BDE-00023313-023315 (designated as “Confidential”).
`Attached as Exhibit 9 is a true and correct copy of a document produced by BDE
`10.
`bearing Bates Nos. BDE-00023316-023332 (designated as “Confidential”).
`Attached as Exhibit 10 is a true and correct copy of a document produced by BDE
`11.
`bearing Bates Nos. BDE-00064578-064589 (designated as “Attorneys’ Eyes Only”).
`Attached as Exhibit 11 is a true and correct copy of a document produced by BDE
`12.
`bearing Bates Nos. BDE-00064425-064426 (designated as “Attorneys’ Eyes Only”).
`Attached as Exhibit 12 is a true and correct copy of a document produced by BDE
`13.
`bearing Bates Nos. BDE-00064642 (designated as “Attorneys’ Eyes Only”).
`Attached as Exhibit 13 is a true and correct copy of a document produced by BDE
`14.
`bearing Bates Nos. BDE-00064438-64439 (designated as “Attorneys’ Eyes Only”).
`Attached as Exhibit 14 is a true and correct copy of a document produced by BDE
`15.
`bearing Bates Nos. BDE-00064104-64105 (designated as “Attorneys’ Eyes Only”).
`Attached as Exhibit 15 is a true and correct copy of a document produced by FRBC
`16.
`bearing Bates Nos. FRBC-00001619-1620 (designated as “Confidential”).
`Attached as Exhibit 16 is a true and correct copy of a document produced by FRBC
`17.
`bearing Bates Nos. FRBC-00001621-1622 (designated as “Confidential”).
`Attached as Exhibit 17 is a true and correct copy of a document produced by FRBC
`18.
`bearing Bates Nos. FRBC-00002100-2103 (designated as “Confidential”).
`Attached as Exhibit 18 is a true and correct copy of a document produced by FRBC
`19.
`bearing Bates Nos. FRBC-00002160-2161 (designated as “Confidential”).
`Attached as Exhibit 19 is a true and correct copy of a document produced by Monto
`20.
`Holdings Pty Ltd. bearing Bates Nos. MONTO-004132-4135 (designated as “Confidential”).
`
`
`DECL OF TODD R. GREGORIAN ISO AMAZON’S
`SUPPLEMENTAL SUBMISSION
`
`
`
`2
`
`CASE NOS.: 5:18-md-02834-BLF;
`5:18-cv-00767-BLF; 5:18-cv-05619-BLF
`
`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
`
`ATTORNEYS AT LAW
`
`FENWICK & WEST LLP
`
`
`
`

`

`Case 5:18-md-02834-BLF Document 864-1 Filed 04/08/23 Page 4 of 4
`
`
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is
`true and correct. Executed in San Francisco, California on this 7th day of April, 2023.
`
`
`/s/ Todd R. Gregorian
`Todd R. Gregorian
`
`
`
`DECL OF TODD R. GREGORIAN ISO AMAZON’S
`SUPPLEMENTAL SUBMISSION
`
`
`
`3
`
`CASE NOS.: 5:18-md-02834-BLF;
`5:18-cv-00767-BLF; 5:18-cv-05619-BLF
`
`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
`
`ATTORNEYS AT LAW
`
`FENWICK & WEST LLP
`
`
`
`