`Case 1:16-cv-00290-MN Document 118-1 Filed 10/30/18 Page 1 of 2 PageID #: 2962
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`EXHIBIT 1
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`
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`Case 1:16-cv-00290-MN Document 118-1 Filed 10/30/18 Page 2 of 2 PageID #: 2963
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`Carlson, Erik
`
`From:
`Sent:
`To:
`Cc:
`
`Subject:
`
`Villarreal, Jose
`Thursday, October 18, 2018 7:01 PM
`Sam Joyner
`Chiji Offor; WSGR - OVT/IP Bridge; Bindu Palapura; David Ellis Moore;
`TeamIPB_Omni_DE_290; Alicia Cary-Howell
`Markman Evidence - Godo Kaisha IP Bridge 1 v. OmniVision Ltd., No. 1:16-CV-290 (D.
`Del.)
`
`Categories:
`
`OmniVision - IPB 1
`
`Sam:
`Over our discovery meet and confer of earlier today the parties mutually agreed not to take the depositions of the other
`side’s experts submitting declarations as part of the Markman hearing. We also notified IPB that at this time
`OmniVision does not intend to bring any expert to testify at Markman, in particular as Dr. Yang is in sabbatical in
`Thailand and it would very burdensome, if not impossible given his commitments, to come to Delaware to testify. IPB
`stated that it would object to the use of any of OmniVision’s expert’s declaration as evidence for the Court’s
`consideration at Markman. When I asked for an explanation and legal basis for the objection IPB declined to elaborate.
`
`As should be clear to IPB, OmniVision does intend to rely on its experts’ declarations as extrinsic evidence for the Court’s
`consideration for claim construction purposes, including at the Markman Hearing. These declarations are already part
`of the Markman record as they were submitted as part of OmniVision’s briefing. If IPB intends to object to
`OmniVision’s use of its experts’ declarations as extrinsic evidence please state the legal basis for doing so and notify us
`when IPB intends to file a motion to preclude this evidence. As the Markman hearing is less than two weeks from today
`any delay by IPB in providing a substantive response to this email would be highly prejudicial to OmniVision.
`
`We look forward to your response.
`
`Thank you
`Jose
`
`Jose C. Villarreal – Partner IP Litigation | Wilson Sonsini Goodrich & Rosati | 900 South Capital of Texas Highway, Las Cimas IV, Fifth Floor | Austin,
`TX 78746 | Main: 512.338.5400 | Direct: 512.338.5424 | Facsimile: 512.338.5499 | Mobile: 512.694.7061 | Email jvillarreal@wsgr.com |
`
`1
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