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`Case 5:20-cv-05676-EJD Document 23-2 Filed 09/25/20 Page 1 of 3
`
`IRELL & MANELLA LLP
`Morgan Chu (70446)
`MChu@irell.com
`Benjamin W. Hattenbach (186455)
`BHattenbach@irell.com
`C. Maclain Wells (221609)
`MWells@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile:
`(310) 203-7199
`
`Attorneys for Defendant
`DEMARAY LLC
`
`APPLIED MATERIALS, INC.,
`
`
`Plaintiff,
`
`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
`SAN JOSE DIVISION
`
`)
`)
`)
`)
`)
`)
`)
`)
`)
`)
`
`Case No. 5:20-cv-05676-EJD
`
`DECLARATION OF C. MACLAIN
`WELLS IN SUPPORT OF DEMARAY
`LLC’S OPPOSITION TO APPLIED
`MATERIALS’ MOTION FOR
`PRELIMINARY INJUNCTION
`
`
`
`
`DEMARAY LLC,
`
`
`vs.
`
`Defendant.
`
`
`
`
`DECLARATION OF C. MACLAIN WELLS
`I, C. Maclain Wells, the undersigned, declare as follows:
`1.
`I am counsel at the law firm of Irell & Manella LLP, counsel for Defendant
`Demaray LLC (“Demaray”). I am a member in good standing of the State Bar of California and
`have been duly licensed to practice law before all of the courts of the State of California. I submit
`this declaration in support of Demaray’s Opposition to Applied Materials’ Motion for Preliminary
`Injunction. I have personal knowledge of the matters set forth in this declaration and, if called as a
`witness, could testify to its contents.
`2.
`Attached hereto as Exhibit 1 is a true and correct copy of U.S Patent No. 7,544,276.
`3.
`Attached hereto as Exhibit 2 is a true and correct copy of U.S Patent No. 7,381,657.
`
`10878866
`
`
`WELLS DECLARATION IN SUPPORT OF OPPOSITION TO
`MOTION FOR PRELIMINARY INJUNCTION
`
`
`
`
`
`Case 5:20-cv-05676-EJD Document 23-2 Filed 09/25/20 Page 2 of 3
`
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`4.
`Attached hereto as Exhibit 3 is a true and correct copy of a press release
`downloaded from http://www.appliedmaterials.com/company/news/press-
`releases/1998/09/applied-komatsu-technology-announces-restructuring.
`5.
`Attached hereto as Exhibit 4 is a true and correct copy of a web page downloaded
`from https://www.samsung.com/us/sas/Business/Overview.
`6.
`Attached hereto as Exhibit 5 is a true and correct copy of a web page downloaded
`from https://www.intel.com/content/www/us/en/corporate-responsibility/intel-in-texas.html.
`7.
`Attached hereto as Exhibit 6 is a true and correct copy of a web page downloaded
`from http://www.appliedmaterials.com/company/contact/locations.
`8.
`Attached hereto as Exhibit 7 is a true and correct copy of a document titled Applied
`Materials, Inc. Project Summary downloaded from
`https://www.austintexas.gov/edims/document.cfm?id=303541.
`9.
`Attached hereto as Exhibit 8 is a true and correct copy of a web page downloaded
`from https://angstromengineering.com/products/evovac/.
`10.
`Attached hereto as Exhibit 9 is a true and correct copy of a web page downloaded
`from https://angstromengineering.com/tech/fixturing/substrate-biasing/.
`11.
`Attached hereto as Exhibit 10 is a true and correct copy of a web page downloaded
`from http://www.ulvac.com/systems/PVD/PVD300mm/PVD300mmEntron.
`12.
`Attached hereto as Exhibit 11 is a true and correct copy of a web page downloaded
`
`from
`https://www.lesker.com/newweb/vacuum_systems/deposition_systems_pvd_prolinepvd200.cfm.
`13.
`Attached hereto as Exhibit 12 is a true and correct copy of a web page downloaded
`from https://www.dentonvacuum.com/products-technologies/magnetron-sputtering/discovery/.
`14.
`Attached hereto as Exhibit 13 is a true and correct copy of a document titled
`Discovery Multi-Cathode Sputter Deposition Platform downloaded from
`https://info.dentonvacuum.com/hubfs/Content%20Assets/Data%20Sheets/Discovery_635-
`785_brochure_web.pdf.
`15.
`Attached hereto as Exhibit 14 is a true and correct copy of a document titled
`
`10878866
`
`
`- 2 -
`
`WELLS DECLARATION IN SUPPORT OF OPPOSITION TO
`MOTION FOR PRELIMINARY INJUNCTION
`
`
`
`Case 5:20-cv-05676-EJD Document 23-2 Filed 09/25/20 Page 3 of 3
`
`Applied Materials Inc. (NASDAQ: AMAT) Q2 2020 Earnings Call Transcript downloaded from
`https://news.alphastreet.com/applied-materials-inc-nasdaq-amat-q2-2020-earnings-call-transcript/.
`16.
`Attached hereto as Exhibit 15 is a true and correct copy of a web page captured
`from https://www.kbvresearch.com/physical-vapor-deposition-market/.
`17.
`Attached hereto as Exhibit 16 is a true and correct copy of Defendant Intel
`Corporation’s Answer And Affirmative Defenses in Case No. 6:20-CV-00634, filed as ECF No.
`19 in in the United States District Court for the Western District of Texas, Waco Division.
`
`Executed on September 25, 2000 in Sebastopol, California. I declare under penalty of
`perjury that the foregoing is true and correct.
`
`
`
`
`
`
`
`
`
`
`/s/ C. Maclain Wells
`By:
`C. Maclain Wells (CA #221609)
`
`
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`10878866
`
`
`- 3 -
`
`WELLS DECLARATION IN SUPPORT OF OPPOSITION TO
`MOTION FOR PRELIMINARY INJUNCTION
`
`
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