Case 5:20-cv-09341-EJD Document 142-1 Filed 03/23/22 Page 1 of 3
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`YAR R. CHAIKOVSKY (SB# 175421)
`yarchaikovsky@paulhastings.com
`PHILIP OU (SB# 259896)
`philipou@paulhastings.com
`JOSEPH J. RUMPLER, II (SB# 296941)
`josephrumpler@paulhastings.com
`DAVID OKANO (SB#278485)
`davidokano@paulhastings.com
`ANDY LEGOLVAN (SB# 292520)
`andylegolvan@paulhastings.com
`BORIS LUBARSKY (SB# 324896)
`borislubarsky@paulhastings.com
`PAUL HASTINGS LLP
`1117 S. California Avenue
`Palo Alto, California 94304-1106
`Telephone: 1(650) 320-1800
`Facsimile: 1(650) 320-1900
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`MATTHIAS KAMBER (SB#232147)
`matthiaskamber@paulhastings.com
`PAUL HASTINGS LLP
`101 California Street, 48th Floor
`San Francisco, California 94111
`Telephone: 1(415) 856-7000
`Facsimile: 1(415)856-7100
`Attorneys for Plaintiff
`APPLIED MATERIALS, INC.
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`UNITED STATES DISTRICT COURT
`NORTHERN DISTRICT OF CALIFORNIA
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`APPLIED MATERIALS, INC.,
`Plaintiff,
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`vs.
`DEMARAY LLC,
`Defendant.
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`CASE NO. 5:20-cv-09341-EJD
`DECLARATION OF BORIS
`LUBARSKY IN SUPPORT OF
`APPLIED MATERIALS, INC.’S
`OPPOSITION TO DEMARAY LLC’S
`MOTION TO AMEND ITS ANSWER
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`DECLARATION OF BORIS LUBARSKY
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`Case 5:20-cv-09341-EJD Document 142-1 Filed 03/23/22 Page 2 of 3
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`I, Boris Lubarsky, hereby declare as follows:
`1.
`I am an associate with the law firm Paul Hastings LLP, counsel for the Plaintiff
`Applied Materials, Inc. (“Applied”). I have personal knowledge of the facts contained in the
`declaration and, if called upon to do so, I could and would testify competently to the matters set
`forth herein.
`Attached as Exhibit A are relevant excerpts of Demaray’s Second Supplemental
`2.
`Preliminary Infringement Contentions served on April 15, 2021 in the customer litigation Demaray
`LLC v. Samsung Electronics Co., LTD, et al. 6:20-cv-00636-ADA.
`Attached as Exhibit B are relevant excerpts of Demaray’s Third Supplemental
`3.
`Preliminary Infringement Contentions served on August 17, 2021 in the customer litigation
`Demaray LLC v. Samsung Electronics Co., LTD, et al. 6:20-cv-00636-ADA.
`Attached as Exhibit C are relevant excerpts of Demaray’s Fourth Supplemental
`4.
`Preliminary Infringement Contentions served on December 24, 2021 in the customer litigation
`Demaray LLC v. Samsung Electronics Co., LTD, et al. 6:20-cv-00636-ADA.
`Attached as Exhibit D are relevant excerpts of technical specification regarding the
`5.
`Comet component used in the Cirrus chamber which Applied produced to Demaray on January 15,
`2021.
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`Attached as Exhibit E are relevant excerpts of the Cirrus PVD Chamber Manual
`6.
`which Applied produced to Demaray on January 21, 2021.
`Attached as Exhibit F is a copy of Keith Miller’s, a Director of Engineering at
`7.
`Applied and corporate representative, declaration explaining the electrical schematics for Applied’s
`Cirrus chamber which Applied produced to Demaray on May 18, 2021.
`Attached as Exhibit G are relevant excerpts of Keith Miller’s February 9, 2021
`8.
`deposition as Applied’s corporate representative regarding the configuration and operation of
`Applied’s PVD chambers.
`Attached as Exhibit H is a copy of Demaray’s counsel’s August 30, 2021 letter to
`9.
`counsel for Applied and Intel.
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`DECLARATION OF BORIS LUBARSKY
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`Case 5:20-cv-09341-EJD Document 142-1 Filed 03/23/22 Page 3 of 3
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`Attached as Exhibit I is a copy of Demaray’s counsel’s February 1, 2022 email and
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`attachment to Applied’s counsel.
`Attached as Exhibit J are relevant excerpts of a redline comparing Demaray’s
`11.
`Fourth Supplemental Preliminary Infringement Contentions served on December 27, 2021 with
`Demaray’s Fifth Supplemental Preliminary Infringement Contentions served on March 4, 2022 in
`the customer litigation Demaray LLC v. Intel Corp., 6:20-cv-00634-ADA.
`Attached as Exhibit K are relevant excerpts of a redline comparing Demaray’s
`12.
`Fourth Supplemental Preliminary Infringement Contentions served on December 27, 2021 with
`Demaray’s Fifth Supplemental Preliminary Infringement Contentions served on March 9, 2022 in
`the customer litigation Demaray LLC v. Samsung Electronics Co., LTD, et al. 6:20-cv-00636-ADA.
`Attached as Exhibit L is a technical specification regarding the Comet component’s
`13.
`frequency response which Applied produced to Demaray on September 2021.
`Attached as Exhibit M is a copy of Demaray’s counsel’s February 2, 2022 email to
`14.
`Applied’s counsel.
`Attached as Exhibit N is a copy of Demaray’s counsel’s February 3, 2022 email to
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`Applied’s counsel.
`Attached as Exhibit O is a copy of Demaray’s counsel’s February 11, 2022 email
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`to Applied’s counsel.
`I declare under penalty of perjury that the foregoing is true and correct.
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`DATED: March 23, 2022
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`By: /s/ Boris Lubarsky
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`Boris Lubarsky
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`DECLARATION OF BORIS LUBARSKY
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