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`Case 5:20-cv-09341-EJD Document 133-1 Filed 03/09/22 Page 1 of 2
`
`IRELL & MANELLA LLP
`Morgan Chu (70446)
`MChu@irell.com
`Benjamin W. Hattenbach (186455)
`BHattenbach@irell.com
`Samuel K. Lu (171969)
`SLu@irell.com
`Olivia L. Weber (319918)
`OWeber@irell.com
`1800 Avenue of the Stars, Suite 900
`Los Angeles, California 90067-4276
`Telephone: (310) 277-1010
`Facsimile:
`(310) 203-7199
`
`FOLIO LAW GROUP PLLC
`C. Maclain Wells (221609)
`Maclain@foliolaw.com
`2376 Pacific Ave.
`San Francisco, CA 94115
`(415) 562-8632
`
`Attorneys for Defendant
`DEMARAY LLC
`
`UNITED STATES DISTRICT COURT
`
`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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`
`
`11073673
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`Case No. 5:20-cv-09341-EJD
`
`DECLARATION OF OLIVIA L. WEBER
`IN SUPPORT OF DEMARAY LLC'S
`NOTICE OF MOTION AND MOTION TO
`AMEND ITS ANSWER TO ADD
`AFFIRMATIVE COUNTERCLAIMS FOR
`INFRINGEMENT
`
`WEBER DECLARATION ISO
`MOTION TO AMEND
`(Case No. 5:20-cv-09341-EJD)
`
`
`
`Case 5:20-cv-09341-EJD Document 133-1 Filed 03/09/22 Page 2 of 2
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`DECLARATION OF OLIVIA L. WEBER
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`I, Olivia L. Weber, hereby declare as follows:
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`1.
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`I am an attorney at the law firm of Irell & Manella LLP, counsel for Defendant
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`Demaray LLC (“Demaray”), and am admitted to practice in the United States District Court,
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`Northern District of California. I have personal knowledge of each fact stated in this declaration
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`and, if called as a witness, I could and would competently and truthfully testify thereto.
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`2.
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`3.
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`Attached as Exhibit 1 is a copy of Demaray's Proposed Amended Answer.
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`Attached as Exhibit 2 is a redlined copy of Demaray's Proposed Amended Answer,
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`which reflects Demaray's proposed amendments.
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`4.
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`Attached as Exhibit 3 is the cover page of Plaintiff Applied Materials Inc.'s
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`("Applied") First Supplemental Objections and Responses to Demaray's Interrogatories, Set One,
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`12
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`which designates the entire document as "CONFIDENTIAL – OUTSIDE COUNSEL EYES
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`13
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`ONLY."
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`5.
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`Attached as Exhibit 4 is an excerpt from a November 4, 2021 discovery hearing in
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`co-pending Texas cases. Demaray LLC v. Intel Corp., Case No. 6:20-cv-00634 (W.D. Tex.);
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`Demaray LLC v. Samsung Electronics, Co., et al., Case No. 6:20-cv-00636 (W.D. Tex.)
`
`(collectively, the "Texas cases"). Applied in this case shares counsel with the defendants in the
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`Texas cases.
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`6.
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`Attached as Exhibit 5 is an excerpt from a September 27, 2021 discovery hearing in
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`20
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`the Texas cases.
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`7.
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`Attached as Exhibit 6 is an excerpt from an August 17, 2021 claim construction
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`hearing in the Texas cases.
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`Executed on March 9, 2022 in Newport Beach, California. I declare under penalty of
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`perjury that the foregoing is true and correct.
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`Dated: March 9, 2022
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`
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`Respectfully submitted,
`IRELL & MANELLA LLP
`
`By: /s/ Olivia L. Weber
`Olivia L. Weber
`Attorneys for Defendant DEMARAY LLC
`
`- 1 -
`
`WEBER DECLARATION ISO
`MOTION TO AMEND
`(Case No. 5:20-cv-009341-EJD)
`
`11073673
`
`
`
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