Case 1:13-cv-00919-LPS Document 359 Filed 04/15/21 Page 1 of 8 PageID #: 44443
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`AREND! S.A.R.L.,
`
`Plaintiff,
`
`C.A. No. 13-919-LPS
`
`V.
`
`GOOGLELLC,
`
`Defendant.
`
`Original Version Filed: April 8, 2021
`Public Version Filed: April 15, 2021
`
`DECLARATION OF MAX STRAUS IN SUPPORT OF AREND! S.A.R.L.'S
`ANSWERING BRIEF IN OPPOSITION TO DEFENDANT GOOGLE LLC'S
`MOTION FOR SUMMARY JUDGMENT OF NON-INFRINGEMENT
`
`I, Max Strnus, hereby declare as follows.
`
`1.
`
`I am over 18 years of age, of sound mind, and othe1wise competent to make this
`
`declaration. The evidence set out in the foregoing Declaration is based on my personal knowledge.
`
`2.
`
`I am an attorney at the law fnm Susman Godfrey LLP, counsel of record for
`
`Plaintiff, Arendi S.a.r.l. in the above-captioned action. I am admitted pro hac vice to practice
`
`before this Court.
`
`Attached as Exhibit 1 is a trne and coITect copy of U.S. Patent No. 7,917,843.
`
`3.
`
`4.
`
`5.
`
`Attached as Exhibit 3 is a hue and hue and coITect copy of exce1pts from the
`
`h·anscript of the deposition of Dr. Ma1tin Rinard taken on December 17, 2021.
`
`6.
`
`Atta.ched as Exhibit 4 is a trne and h11e and coITect copy of Programming Reference
`
`for the Win32 A.PI produced to Google LLC ("Google") in this action as AREND!_ G332606 - 09.
`
`1
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`AREND! S.A.R.L.,
`
`Plaintiff,
`
`C.A. No. 13-919-LPS
`
`V.
`
`GOOGLELLC,
`
`Defendant.
`
`Original Version Filed: April 8, 2021
`Public Version Filed: April 15, 2021
`
`DECLARATION OF MAX STRAUS IN SUPPORT OF AREND! S.A.R.L.'S
`ANSWERING BRIEF IN OPPOSITION TO DEFENDANT GOOGLE LLC'S
`MOTION FOR SUMMARY JUDGMENT OF NON-INFRINGEMENT
`
`I, Max Strnus, hereby declare as follows.
`
`1.
`
`I am over 18 years of age, of sound mind, and othe1wise competent to make this
`
`declaration. The evidence set out in the foregoing Declaration is based on my personal knowledge.
`
`2.
`
`I am an attorney at the law fnm Susman Godfrey LLP, counsel of record for
`
`Plaintiff, Arendi S.a.r.l. in the above-captioned action. I am admitted pro hac vice to practice
`
`before this Court.
`
`Attached as Exhibit 1 is a trne and coITect copy of U.S. Patent No. 7,917,843.
`
`3.
`
`4.
`
`5.
`
`Attached as Exhibit 3 is a hue and hue and coITect copy of exce1pts from the
`
`h·anscript of the deposition of Dr. Ma1tin Rinard taken on December 17, 2021.
`
`6.
`
`Atta.ched as Exhibit 4 is a trne and h11e and coITect copy of Programming Reference
`
`for the Win32 A.PI produced to Google LLC ("Google") in this action as AREND!_ G332606 - 09.
`
`1
`
`
`
`Case 1:13-cv-00919-LPS Document 359 Filed 04/15/21 Page 2 of 8 PageID #: 44444
`
`7.
`
`Attached
`
`as Exhibit
`
`5
`
`is
`
`a
`
`true
`
`and
`
`correct
`
`copy
`
`of …/
`
`src/com/android/calendar/Utils.java, from version 8.0.0_r1 of Android Open Source Project
`
`Calendar,
`
`produced
`
`to
`
`
`for
`
`download
`
`from
`
`https://android.googlesource.com/platform/packages/apps/Calendar/+/refs/tags/android-8.0.0_r1
`
`and
`
`https://android.googlesource.com/platform/packages/apps/Calendar/+archive/956525423e51315
`
`015d6902e3b9487e72e9f4885.tar.gz.
`
`8.
`
`Attached
`
`as Exhibit
`
`6
`
`is
`
`a
`
`true
`
`and
`
`correct
`
`copy
`
`of …/
`
`core/java/android/widget/TextView.java, from version 8.0.0_r1 of the Android Open Source
`
`Project
`
`“base”
`
`framework,
`
`produced
`
`to
`
`
`for
`
`download
`
`from
`
`https://android.googlesource.com/platform/frameworks/base/+/refs/tags/android-8.0.0 r1
`
`and
`
`https://android.googlesource.com/platform/frameworks/base/+archive/899eecd41a6bf506766dfa
`
`64f9f17173add74cbc.tar.gz.
`
`9.
`
`Attached
`
`as Exhibit
`
`7
`
`is
`
`a
`
`true
`
`and
`
`correct
`
`copy
`
`of …/
`
`core/java/android/text/util/Linkify.java, from version 8.0.0_r1 of the Android Open Source Project
`
`“base”
`
`framework,
`
`produced
`
`to
`
`
`for
`
`download
`
`from
`
`https://android.googlesource.com/platform/frameworks/base/+/refs/tags/android-8.0.0_r1
`
`and
`
`https://android.googlesource.com/platform/frameworks/base/+archive/899eecd41a6bf506766dfa
`
`64f9f17173add74cbc.tar.gz.
`
`10.
`
`Attached as Exhibit 8 is a true and correct copy of Android Developers: Linkify
`
`documentation, produced to Google as ARENDI_G330221 – 35.
`
`11.
`
`Attached as Exhibit 9 is a true and correct copy of Android Developers: Intent
`
`documentation, produced to Google as ARENDI_G329816 - 30170.
`
`
`
`2
`
`
`
`
`
`Case 1:13-cv-00919-LPS Document 359 Filed 04/15/21 Page 3 of 8 PageID #: 44445
`
`12.
`
`Attached
`
`as Exhibit 10
`
`is
`
`a
`
`true
`
`and
`
`correct
`
`copy of …/
`
`core/java/android/text/style/URLSpan.java, from version 8.0.0_r1 of the Android Open Source
`
`Project
`
`“base”
`
`framework,
`
`produced
`
`to
`
`
`for
`
`download
`
`from
`
`https://android.googlesource.com/platform/frameworks/base/+/refs/tags/android-8.0.0_r1
`
`and
`
`https://android.googlesource.com/platform/frameworks/base/+archive/899eecd41a6bf506766dfa
`
`64f9f17173add74cbc.tar.gz.
`
`13.
`
`Lodged with the Court on April 7, 2021 (D.I. 344) and attached hereto as Exhibit
`
`11 is a true and correct copy of the recording tilted Google I/O Keynote, produced to Google as
`
`ARENDI_G332853.
`
`14.
`
`Attached as Exhibit 12 is a true and correct copy of GOOG00018560, produced by
`
`Google in this litigation.
`
`15.
`
`Attached as Exhibit 13 is a true and correct copy of the document titled Google AI
`
`Blog: The Machine Learning Behind Android Smart Linkify, produced by Google in this litigation
`
`as GOOG00016448 – 50.
`
`16.
`
`17.
`
`
`
`
`
`
`
`
`
`18.
`
`Attached as Exhibit 16 is a true and correct copy of Android Developers: TextLinks
`
`documentation, produced to Google as ARENDI_G330655 - 66.
`
`19.
`
`Attached as Exhibit 17 is a true and correct copy of Android Developers:
`
`TextClassifier documentation, produced to Google as ARENDI_G330622 - 45.
`
`
`
`3
`
`
`
`
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`Case 1:13-cv-00919-LPS Document 359 Filed 04/15/21 Page 4 of 8 PageID #: 44446
`
`20.
`
`
`
`21.
`
`Attached as Exhibit 19 is a true and correct copy of GOOG00057487 – 88,
`
`
`
`produced by Google in this litigation.
`
`22.
`
`
`
`
`
`23.
`
`Attached as Exhibit 21 is a true and correct copy of Google Play: Google Docs,
`
`produced to Google as ARENDI_G330529 – 32.
`
`24.
`
`Attached as Exhibit 22 is a true and correct copy of Google Play: Google Sheets,
`
`produced to Google as ARENDI_G330537 – 40.
`
`25.
`
`Attached as Exhibit 23 is a true and correct copy of Docs Editors Help: How to Use
`
`Google Docs, produced to Google as ARENDI_G329803 – 04.
`
`26.
`
`Attached as Exhibit 24 is a true and correct copy of Docs Editors Help: Use
`
`Comments and Action Items, produced to Google as ARENDI_G330592 – 94.
`
`27.
`
`Attached as Exhibit 25 is a true and correct copy of Calendar Help: Create an Event,
`
`produced to Google as ARENDI_G329390 – 92.
`
`28.
`
`Attached as Exhibit 26 is a true and correct copy of Calendar Help: Add Reminders
`
`in Google Calendar, produced to Google as ARENDI_G329025 – 27.
`
`29.
`
`Attached as Exhibit 27 is a true and correct copy of Tasks Help: Add or Edit a Task,
`
`produced to Google as ARENDI_G329022 – 24.
`
`30.
`
`Attached as Exhibit 28 is a true and correct copy of Sites Help: How to Use Google
`
`Sites, produced to Google as ARENDI_G329805 – 06.
`
`
`
`4
`
`
`
`
`
`Case 1:13-cv-00919-LPS Document 359 Filed 04/15/21 Page 5 of 8 PageID #: 44447
`
`31.
`
`Attached as Exhibit 29 is a true and correct copy of the Court’s Memorandum
`
`Order, dated December 15, 2020, and docketed as D.I. 152 in Arendi S.A.R.L. v. HTC Corp., C.A.
`
`No. 12-1600-LPS.
`
`32.
`
`Attached as Exhibit 30 is a true and correct copy of Docs Editors Help: Google
`
`Docs, produced to Google as ARENDI_G329772 – 74.
`
`33.
`
`Attached as Exhibit 31 is a true and correct copy of Docs Editors Help: Google
`
`Sheets, produced to Google as ARENDI_G329793 – 95.
`
`34.
`
`Attached as Exhibit 32 is a true and correct copy of Docs Editors Help: Google
`
`Slides, produced to Google as ARENDI_G329796 – 97.
`
`35.
`
`Attached as Exhibit 33 is a true and correct copy of Docs Editors Help: Edit &
`
`Format a Spreadsheet, produced to Google as ARENDI_G329405 – 06.
`
`36.
`
`Attached as Exhibit 34 is a true and correct copy of Docs Editors Help: Create, Find
`
`or Download a File, produced to Google as ARENDI_G329395– 97.
`
`37.
`
`Attached as Exhibit 35 is a true and correct copy of Messages Help: Send & Receive
`
`Text Messages in Messages, produced tot Google as ARENDI_G330580 – 81.
`
`38.
`
`Attached as Exhibit 36 is a true and correct copy of Hangouts Help: Start a Hangout,
`
`produced to Google as ARENDI_G330595 – 96.
`
`39.
`
`Attached as Exhibit 37 is a true and correct copy of Messages Help: Get Started
`
`with Messages, produced to Google as ARENDI_G329757 – 58.
`
`40.
`
`Attached as Exhibit 38 is a true and correct copy of U.S. Patent No. 5,708,804,
`
`produced by Motorola as ARENDI-DEFS00009653 – 71.
`
`41.
`
`Attached as Exhibit 39 is a true and correct copy of Google Developers: Google
`
`Maps Intents for Android, produced to Google as ARENDI_G329775 – 92.
`
`
`
`5
`
`
`
`
`
`Case 1:13-cv-00919-LPS Document 359 Filed 04/15/21 Page 6 of 8 PageID #: 44448
`
`42.
`
`
`
`
`
`43.
`
`Attached as Exhibit 41 is a true and correct copy of Android Developers:
`
`Understand the Activity Lifecycle, produced to Google as ARENDI_G331167 – 93.
`
`44.
`
`Attached as Exhibit 42 is a true and correct copy of Android Developers: Intents
`
`and Intent Filters, produced to Google as ARENDI_G330171 – 92.
`
`45.
`
`Attached as Exhibit 43 is a true and correct copy of Android Developers:
`
`Application Fundamentals, produced to Google as ARENDI_G329218 – 27.
`
`46.
`
`Attached as Exhibit 44 is a true and correct copy of excerpts from Android
`
`Developers: View, produced to Google as ARENDI_G331204 – 2042.
`
`47.
`
`Attached
`
`as Exhibit 45
`
`is
`
`a
`
`true
`
`and
`
`correct
`
`copy of …/
`
`android/calendar/EventInfoFragment.java, from version 8.0.0_r1 of Android Open Source Project
`
`Calendar,
`
`produced
`
`to
`
`
`for
`
`download
`
`from
`
`https://android.googlesource.com/platform/packages/apps/Calendar/+/refs/tags/android-8.0.0_r1
`
`and
`
`https://android.googlesource.com/platform/packages/apps/Calendar/+archive/956525423e51315
`
`015d6902e3b9487e72e9f4885.tar.gz.
`
`48.
`
`Attached as Exhibit 46 is a true and correct copy of excerpts from the transcript of
`
`the deposition of Dr. Earl Sacerdoti taken on January 20, 2021.
`
`49.
`
`Lodged with the Court on April 7, 2021 are true and correct copies of certain video
`
`files cited in the expert reports of Dr. Trevor Smedley and produced to Google in conjunction with
`
`those reports. D.I. 344. The following table reflects both the names of the lodged video files and
`
`the corresponding exhibit number by which they are referenced in both the expert reports of Dr.
`
`
`
`6
`
`
`
`
`
`Case 1:13-cv-00919-LPS Document 359 Filed 04/15/21 Page 7 of 8 PageID #: 44449
`
`Trevor Smedley and Plaintiff’s Answering Brief in Opposition to Defendant Google LLC’s
`
`Motion for Summary Judgment of Non-Infringement.
`
`File Name
`A2.1.mp4
`A3.1.mp4
`A3.10.mp4
`A3.9.mp4
`A3.10.mp4
`A4.5.mp4
`A4.10.mp4
`A4.11.mp4
`A4.13.mp4
`A4.15.mp4
`A4.23.mp4
`A5.3.mp4
`A5.4.mp4
`A6.11.mp4
`A7.6.mp4
`A7.34.mp4
`A8.3.mp4
`A8.13.mp4
`A9.12.mp4
`A10.3.mp4
`A10.17.mp4
`A12.3.mp4
`A12.4.mp4
`A13.2.mp4
`A13.5.mp4
`A13.9.mp4
`A13.10.mp4
`A13.11.mp4
`A14.5.mp4
`B3.3.mp4
`B3.4.mp4
`B4.1.mp4
`B4.9.mp4
`B6.2.mp4
`B7.21.mp4
`B8.1.mp4
`B9.1.mp4
`
`Exhibit
`
`A2.1
`A3.1
`A3.10
`A3.9
`A3.10
`A4.5
`A4.10
`A4.11
`A4.13
`A4.15
`A4.23
`A5.3
`A5.4
`A6.11
`A7.6
`A7.34
`A8.3
`A8.13
`A9.12
`A10.3
`A10.17
`A12.3
`A12.4
`A13.2
`A13.5
`A13.9
`A13.10
`A13.11
`A14.5
`B3.3
`B3.4
`B4.1
`B4.9
`B6.2
`B7.21
`B8.1
`B9.1
`7
`
`
`
`
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`
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`Case 1:13-cv-00919-LPS Document 359 Filed 04/15/21 Page 8 of 8 PageID #: 44450
`
`File Name
`B10.2.mp4
`B10.17.mp4
`B11.1.mp4
`B12.3.mp4
`B13.4.mp4
`B13.7.mp4
`B13.8.mp4
`B13.9.mp4
`B15.1.mp4
`C4.11.mp4
`C13.2.mp4
`C13.3.mp4
`C13.9.mp4
`
`Exhibit
`
`B10.2
`B10.17
`B11.1
`B12.3
`B13.4
`B13.7
`B13.8
`B13.9
`B15.1
`C4.11
`C13.2
`C13.3
`C13.9
`
` declare under penalty of perjury that the foregoing is true and correct.
`
` I
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`Executed this 8th day of April, 2021, at Lower Merion Township, Pennsylvania.
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`/s/ Max Straus
`Max Straus
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`8
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