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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`ARENDI S.A.R.L.,
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`Plaintiff,
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` v.
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`MOTOROLA MOBILITY LLC
`f/k/a MOTOROLA MOBILITY, INC.
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`Defendant.
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`ARENDI S.A.R.L.,
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`Plaintiff,
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` v.
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`GOOGLE LLC,
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`Defendant.
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` C.A. No. 12-1601-LPS
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` C.A. No. 13-919-LPS
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`DECLARATION OF IBITUROKO-EMI LAWSON IN SUPPORT OF ARENDI’S
`MOTION TO EXCLUDE IN PART THE EXPERT REPORTS AND TESTIMONY OF
`EDWARD FOX
`
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`I, Ibituroko-Emi Lawson, hereby declare as follows:
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`1.
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`I am over 18 years of age, of sound mind, and otherwise competent to make this
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`declaration. The evidence set out in the foregoing Declaration is based on my personal knowledge.
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`2.
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`I am an attorney at the law firm Susman Godfrey LLP, counsel of record for
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`Plaintiff, Arendi S.à.r.l. (“Arendi”), in the above-captioned action. I am admitted pro hac vice to
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`practice before this Court.
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`3.
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`Attached as Exhibit 1 is a true and correct copy of the Declaration of Brett M.
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`Hutton, Esq. in Support of Plaintiff’s Motion to Strike the Expert Report of Peter Seifert and
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`Preclude Mr. Seifert from Testifying at Trial Regarding Invalidity of the ’940 Patent, together with
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`
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`Case 1:13-cv-00919-LPS Document 365 Filed 05/04/21 Page 2 of 2 PageID #: 46344
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`Exhibit A to that declaration (entitled “Expert Report of Peter Seifert on the Invalidity of U.S.
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`Patent RE39,940”), filed in Advanced Fiber Technologies (AFT) Trust v. J&L Fiber Services, Inc.,
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`No. 07-1191 LEK/DRH (N.D.N.Y. Oct. 1, 2019).
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`4.
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`Together with Kemper Diehl and Neal Belgam, also counsel for Arendi, I met and
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`conferred with counsel for Motorola Mobility LLC and Google LLC (“Defendants”) on March 4,
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`2021. During that call, counsel discussed both Arendi’s instant Daubert motion to exclude against
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`Dr. Fox and Defendants’ own intended motions against Arendi’s experts, Roy Weinstein and M.
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`Laurentius Marais. Defendants had not previously informed Arendi of their intended Daubert
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`motions. Contrary to Defendants’ assertion in their brief, counsel did not meet and confer “the
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`night before” March 5, 2021 (C.A. No. 12-1601-LPS, D.I. 332, at 6), but rather at 12 pm EST
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`during a teleconference proposed by Arendi’s counsel on February 25, 2021.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 4th day of May, 2021, at Houston, Texas.
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`/s/ Ibituroko-Emi Lawson
`Ibituroko-Emi Lawson
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`2
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