`Case 1:12—cv—OO398—GMS Document 24 Filed 02/07/13 Page 1 of 3 Page|D #: 128
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`I-IUMANEYE-S TECHNOLOGIES LTD.
`
`Plafntiflf
`
`V.
`
`SONY CORPORATION, SONY
`CORPORATION OF AMERICA, SONY
`ELECTRONICS INC., SONY MOBILE
`COMMUNICATIONS AB, AND SONY
`MOBILE COMMUNICATIONS (USA) INC.,
`
`Defertdanfs.
`
`
`
`C.A. No. 12-398—GMS
`
`DECLARATION OF IULIANA TANASE IN SUPPORT OF DEFENDANTS’ MOTION
`TO DISMISS PLAINTIFF’S CONTRIBUTORY INFRINGEMENT
`ALLEGATIONS IN THE COMPLAINT FOR FAILURE TO STATE A CLAIM
`
`OF COUNSEL:
`
`John Flock
`
`Walter Hanley
`Michelle Carniaux
`Sheila Mortazavi
`Iuliana Tanase
`KENYON & KENYON LLP
`
`One Broadway
`New York, New York 10004-1050
`(212) 425-7200
`
`Chad M. Shandler (#3 796)
`Elizabeth R. He (#5345)
`RICHARDS, LAYTON & FINGER, P.A.
`One Rodney Square
`920 N. King Street
`Wilmington , DE 19801
`(302) 651-7700
`Shandler@rlf.com
`He@rlf.com
`
`Arrorneysfor Defendants Sony Corporarion,
`Sony Corporation ofAmer:’ca, Sony Efecrronics
`Inc., Sony Mobife Commzmfcarz'on.s‘ AB. Sony
`Mobile Commum'caI'r‘on.s- (USA) Inc.
`
`
`
`Case 1:12-cv-00398-GMS Document 24 Filed 02/07/13 Page 2 of 3 PageID #: 129
`Case 1:12—cv—OO398—GMS Document 24 Filed 02/07/13 Page 2 of 3 Page|D #: 129
`
`I, Iuliana Tanase, am an attorney at law admitted to practice in the States of New York
`
`and New Jersey, and an Associate at Kenyon & Kenyon LLP, counsel for Defendants Sony
`
`Corporation, Sony Corporation of America, Sony Electronics Inc., Sony Mobile
`
`Communications AB and Sony Mobile Communications (USA) Inc.
`
`I was admitted pro hac vice
`
`in this case on January 16, 2013. I make this certification in support of Defendants’ Motion to
`
`Dismiss Plaintiff’s Contributory Infringement Allegations in the Complaint for Failure to State a
`
`Claim.
`
`1.
`
`Attached as Exhibit 1 is a true and correct copy of a document entitled “Digital
`
`Still Cameraflnstruction Manual” for the Cyber-shot camera Model DSC-WX7/WX9, which was
`
`attached to l--luma.nEyes’ ITC complaint as an exhibit during ITC Investigation No. 337-TA-842.
`
`2.
`
`Attached as Exhibit 2 is a true and correct copy of a document entitled “DSC-
`
`WXWWX9 User Guide,” which was attached to HurnanEyes’ ITC complaint as an exhibit during
`
`ITC Investigation No. 337-TA—842 and is available at
`
`littg:Kfesu};1:2L5i'I.sony.com/docsfdvimas22’DSCWX7-WX9 guide;’eng[index.litml.
`
`3.
`
`Attached as Exhibit 3 is a true and correct copy of a document entitled “Xperia
`
`Neo V Extended User guide,” which is available at littp:rU’www-st1ppo1't-
`
`downloadsson mobile.co1nfmtll»’user uidc AB MTll
`
`
`I253-9815.1. df.
`
`
`I declare under penalty of perjury that the foregoing is true and correct, and that this
`
`declaration was executed on this Th day of February, 2013 in New York City, New York.
`
`
`
`Case 1:12-cv-00398-GMS Document 24 Filed 02/07/13 Page 3 of 3 PageID #: 130
`Case 1:12—cv—OO398—GMS Document 24 Filed 02/07/13 Page 3 of 3 Page|D #: 130
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on February 7, 2013, I caused to be filed the foregoing document
`
`with the Clerk of Court using CM/ECF, which will send notification of such filing to counsel of
`
`record, and served true and correct copies of the foregoing on the following counsel as indicated:
`
`BY ELECTRONIC MAIL
`
`Steven J. Balick
`
`Andrew Colin Mayo
`Tiffany Geyer Lydon
`Ashby & Geddes
`500 Delaware Avenue, 8th Floor
`P.O. Box 1150
`
`Wilmington, DE 19899
`sbalick@ashby~geddes.com
`amayo@ashby—geddes.com
`tlydon@ashby—geddes.com
`
`Matthew D. Powers
`
`Steven S. Cherensky
`Paul T . Ehrlich
`
`Stefani C. Smith
`
`Robert L. Gerrity
`TENSEGRITY LAW GROUP LLP
`
`555 Twin Dolphin Drive, Suite 360
`Redwood Shores, CA 94065
`matthew.powers@tensegritylawgroup.com
`Steven.cherensky@tensegritylawgroup.com
`paul.ehrlich@tensegrityiawgroup.corn
`stefani.smith@tensegritylawgroup.com
`robert.gerrity@tensegritylawgroup.com
`
`/s/ Elizabeth R. He
`
`Elizabeth R. He (#5345)
`he@rlf.com
`
`RLFI 8082884v.l
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
