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`Case 1:16-cv-00116-RGA Document 274 Filed 12/08/17 Page 1 of 4 PageID #: 7425
`Case 1:16-cv-00116-RGA Document 274 Filed 12/08/17 Page 1 of 4 PageID #: 7425
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE DISTRICT OF DELAWARE
`
`SOUND VIEW INNOVATIONS, LLC,
`
`)
`
`v.
`FACEBOOK, INC,
`
`Plaintiff,
`
`Defendant
`
`i
`3 Civil Action No. 1:16—cv—1 16 (RGA)
`i
`JURY TRIAL DEMANDED
`i
`REDACTED — PUBLICVERSION
`
`DECLARATION OF EDWARD B. GEIST IN SUPPORT OF
`
`SOUND VIEW INNOVATIONS, LLC’S MOTIONS FOR SUMNIARY JUDGMENT
`
`I, Edward B. Geist, declare that:
`
`1.
`
`I am an attorney with the law firm of Desmarais LLP, counsel of record for
`
`Plaintiff Sound View Innovations, LLC (“Plaintiff’ or “Sound View”) in the above-captioned
`
`matter, and I am admitted pro hac vice to this Court.
`
`I submit this declaration based on personal
`
`knowledge, and if called upon as a witness, I could competently testir'y to the truth of each
`statement herein.
`
`2.
`
`Unless otherwise noted, all highlighting in the foregoing exhibits has been added
`
`for clarity.
`
`3.
`
`Attached hereto as Exhibit
`
`1
`
`is a true and correct copy of US. Patent No.
`
`6,125,371.
`
`4.
`
`Attached hereto as Exhibit 2 is a true and correct copy of US. Patent No.
`
`7,366,786.
`
`5.
`
`Attached hereto as Exhibit 3 is a true and correct copy of US. Patent No.
`
`8,135,860.
`
`

`

`Case 1:16-cv-00116-RGA Document 274 Filed 12/08/17 Page 2 of 4 PageID #: 7426
`Case 1:16-cv-00116-RGA Document 274 Filed 12/08/17 Page 2 of 4 PageID #: 7426
`
`6.
`
`Attached hereto as Exhibit 4 is a true and correct copy of excerpts from Defendant
`
`Facebook, Inc. ’5 Third Amended Invalidity Contentions, dated September 8, 2017, including
`
`exhibits to those contentions.
`
`7.
`
`Attached hereto as Exhibit 5 is a true and correct copy of excerpts from the Expert
`
`Report Of Stephen Gray Regarding Invalidity Of US. Patent Nos. 6,732,181 And 7,366,786,
`
`dated September 20, 2017, including Appendix 4d to that report.
`
`8.
`
`Attached hereto as Exhibit 6 is a true and correct copy of excerpts from the Reply
`
`Expert Report Of Stephen Gray Regarding Invalidity Of US. Patent Nos. 6,732,181 And
`
`7,366,786, dated November 3, 2017.
`
`. 9.
`
`Attached hereto as Exhibit 7 is a true and correct copy of excerpts from the Expert
`
`Report of Jon B. Weissrnan, PhD. Regarding Invalidity of U.S. Patent Nos. 6,125,371 and
`
`8,135,860, dated September 20, 2017, including Appendix C to that report.
`
`10.
`
`Attached hereto as Exhibit 8 is a true and correct copy of excerpts from the Reply
`
`Expert Report of Jon B. Weissrnan, PhD. Regarding Invalidity of US Patent Nos. 6,125,371
`
`and 8,135,860, dated November 3, 2017.
`
`11.
`
`Attached hereto as Exhibit 9 is a true and correct copy of excerpts from the
`
`deposition of Jon B. Weissman, Ph.D. on November 10, 2017.
`
`12.
`
`Attached hereto as Exhibit 10 is a true and correct copy of excerpts from a
`
`document produced by Facebook bearing Bates numbers FBSVi00025168~174.
`
`13.
`
`Attached hereto as Exhibit 11 is a true and correct copy of an excerpted portion of
`
`US. Patent Application No. 08/785,559 to Weinreich, originally filed on January 17, 1997.
`
`

`

`Case 1:16-cv-00116-RGA Document 274 Filed 12/08/17 Page 3 of 4 PageID #: 7427
`Case 1:16-cv-00116-RGA Document 274 Filed 12/08/17 Page 3 of 4 PageID #: 7427
`
`14.
`
`Attached hereto as Exhibit 12 is a true and correct copy of an excerpted portion of
`
`the file history of US. Patent Application No. 08/785,559 to Weinreich, dated January 17, 1997,
`
`titled “New Application Transmittal.”
`
`15.
`
`Attached hereto as Exhibit 13 is a true and correct copy of an excerpted portion of
`
`the file history of US. Patent Application No. 08/785,559 to Weinreich, dated October 30, 1998,
`
`titled “Office Action Summary.”
`
`16.
`
`Attached hereto as Exhibit 14 is a true and correct copy of a portion of the file
`
`history of US. Patent Application No. 08/785,559 to Weinreich, dated May 1, 1999, titled
`
`“Response to Office Action.”
`
`17.
`
`Attached hereto as Exhibit 15 is a true and correct copy of a portion of the file
`
`history of US. Patent Application No. 08/785,559 to Weinreich, dated June 16, 1999, titled
`
`“Declaration of Josephine B. Hardy.”
`
`l8.
`
`Attached hereto as Exhibit 16 is a true and correct copy of excerpts from a
`
`document produced by Facebook bearing Bates numbers FB SV_00139492—530.
`
`19.
`
`Attached hereto as Exhibit 17 is a true and correct copy of excerpts from a
`
`document produced by Facebook bearing Bates numbers PB SV__001 32572—3 652.
`
`20.
`
`Attached hereto as Exhibit 18 is a true and correct copy of Sound View
`
`Innovations, LLC’s Second Set Of Interrogatories To Defendant Facebook, Inc. (Nos. 12—21),
`
`dated April 27, 2017.
`
`21.
`
`Attached hereto as Exhibit 19 is a true and correct copy of excerpts from
`
`Facebook’s Objections And Responses To Plaintiff" 5 Second Set Of Interrogatories (Nos. 12—
`
`21), dated May 26, 2017.
`
`

`

`i- "-
`
`--l
`
`|
`
`Case 1:16-cv-00116-RGA Document 274 Filed 12/08/17 Page 4 of 4 PageID #: 7428
`Case 1:16-cv-00116-RGA Document 274 Filed 12/08/17 Page 4 of 4 PageID #: 7428
`
`22.
`
`Attached hereto as Exhibit 20 is a true and correct copy of excerpts from
`
`Facebook’s Second Supplemental Objections And Responses To Plaintiffs Second Set Of
`
`lnterrogatories (Nos. 12, 13, 16, 18, And 21), dated September 15, 2017.
`
`Executed on December 1, 2017, in New York, New York.
`
`/s/ Edward B. Geist
`
`Edward B. Geist
`
`

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