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`Case 5:20-cv-05676-EJD Document 39-1 Filed 11/23/20 Page 1 of 2
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`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
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`Attorneys for Defendant
`DEMARAY LLC
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`UNITED STATES DISTRICT COURT
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`NORTHERN DISTRICT OF CALIFORNIA
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`SAN JOSE DIVISION
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`APPLIED MATERIALS, INC.,
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`Plaintiff,
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`DEMARAY LLC,
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`vs.
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`Defendant.
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` Case No. 5:20-cv-05676-EJD
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`DECLARATION OF C. MACLAIN
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`WELLS IN SUPPORT OF DEMARAY
`LLC’S MOTION TO DISMISS
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`WELLS DECLARATION ISO MOTION TO DISMISS
`(Case No. 5:20-cv-05676-EJD)
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`Case 5:20-cv-05676-EJD Document 39-1 Filed 11/23/20 Page 2 of 2
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`DECLARATION OF C. MACLAIN WELLS
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`I, C. Maclain Wells, hereby declare as follows:
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`1.
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`I am counsel at the law firm of Irell & Manella LLP, counsel for Defendant
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`Demaray LLC (“Demaray”). I am a member in good standing of the State Bar of California and
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`have been duly licensed to practice law before all of the courts of the State of California. I submit
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`this declaration in support of Demaray’s Motion to Dismiss. I have personal knowledge of the
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`matters set forth in this declaration and, if called as a witness, could testify to its contents.
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`2.
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`Attached as Exhibit 1 is a copy of the complaint filed as Dkt. 1 in Demaray LLC v.
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`Intel Corp., No. 6:20-cv-00634-ADA, in the United States District Court for the Western District
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`of Texas, Waco Division.
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`3.
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`Attached as Exhibit 2 is a copy of the complaint filed as Dkt. 1 in Demaray LLC v.
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`Samsung Electronics Co., Ltd., No. 6:20-cv-00636-ADA, in the United States District Court for
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`the Western District of Texas, Waco Division.
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`4.
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`7.
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`Attached as Exhibit 3 is a copy of U.S. Patent No. 7,544,276.
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`Attached as Exhibit 4 is a copy of U.S. Patent No. 7,381,657.
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`Attached as Exhibit 5 is a copy of an email filed as Dkt. 27-2 in this case.
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`Attached as Exhibit 6 is a copy of the joint case readiness status report for the Intel
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`and Samsung cases in Texas filed as Dkt. 24 in Demaray LLC v. Samsung Electronics Co., Ltd.,
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`No. 6:20-cv-00636-ADA, in the United States District Court for the Western District of Texas,
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`Waco Division.
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`8.
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`Attached as Exhibit 7 is a copy of the scheduling order for the Intel and Samsung
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`cases in Texas filed as Dkt. 33 in Demaray LLC v. Samsung Electronics Co., Ltd., No. 6:20-cv-
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`00636-ADA, in the United States District Court for the Western District of Texas, Waco Division.
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`Executed on November 23, 2020 in Sebastopol, California. I declare under penalty of
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`perjury that the foregoing is true and correct.
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`By: /s/ C. Maclain Wells
`C. Maclain Wells
`Attorneys for Defendant DEMARAY LLC
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`- 1 -
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`WELLS DECLARATION ISO MOTION TO DISMISS
`(Case No. 5:20-cv-05676-EJD)
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`