`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`GODO KAISHA IP BRIDGE 1,
`
`Plaintiff,
`
`v.
`
`OMNIVISION TECHNOLOGIES, INC.,
`
`Defendant.
`
`Case No. 1:16-cv-00290-MN
`
`DECLARATION OF DIYANG LIU IN SUPPORT OF OMNIVISION’S
`DISCOVERY LETTER IN ADVANCE OF THE
`DECEMBER 3, 2018 TELEPHONIC HEARING
`
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Stephanie E. O’Byrne (#4446)
`POTTER ANDERSON & CORROON LLP
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`sobyrne@potteranderson.com
`
`Attorneys for Defendant OmniVision
`Technologies, Inc.
`
`OF COUNSEL:
`
`James C. Yoon
`WILSON SONSINI GOODRICH & ROSATI
`Professional Corporation
`650 Page Mill Road
`Palo Alto, CA 94304-1050
`Tel: (650) 493-9300
`
`Edward G. Poplawski
`Erik J. Carlson
`Lisa D. Zang
`WILSON SONSINI GOODRICH & ROSATI
`633 West Fifth Street, Suite 1550
`Los Angeles, CA 90071
`Tel: (323) 210-2901
`
`Jose C. Villarreal
`Henry Pan
`Diyang Liu
`WILSON SONSINI GOODRICH & ROSATI
`900 S. Capital of Texas Highway
`Las Cimas IV, 5th Floor
`Austin, TX 78746
`Tel: (512) 338-5400
`
`Dated: November 28, 2018
`6013804 / 43303
`
`
`
`Case 1:16-cv-00290-MN Document 131 Filed 11/28/18 Page 2 of 4 PageID #: 3149
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`I, Diyang Liu, declare as follows:
`
`1.
`
`I am an attorney at Wilson Sonsini Goodrich & Rosati, counsel for Defendant
`
`OmniVision Technologies, Inc. (“OmniVision”) in the above-referenced action. I submit this
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`declaration in support of OmniVision’s Letter Brief in Advance of the December 3, 2018
`
`Telephonic Hearing. The matters set forth herein are based upon my personal knowledge, and, if
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`called as a witness, I could and would competently testify thereto.
`
`2.
`
`Attached as Exhibit A is a true and correct copy of Exhibit 5 to Plaintiff Godo
`
`Kaisha IP Bridge 1’s (“Godo”) Amended Infringement Contentions for United States Patent
`
`6,794,677, OV5650 (OmniBSI), served on November 16, 2018.
`
`3.
`
`Attached as Exhibit B is a true and correct copy of Godo’s Third Supplemental
`
`Objections and Responses to OmniVision’s First Set of Interrogatories (Nos. 1-16), served
`
`November 16, 2018.
`
`4.
`
`Attached as Exhibit C is a true and correct copy of excerpts of the transcript of
`
`the November 12, 2018 deposition of Huawei Device USA, including pages 1–5 and 105.
`
`5.
`
`Attached as Exhibit D is a true and correct copy of Godo’s Objections and
`
`Responses to OmniVision’s First Set of Interrogatories (Nos. 1-16), served February 26, 2018.
`
`Here, on pages 38 and 39, Godo initially identified twelve Japanese-language documents with
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`Bates
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`ranges
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`290-IPB-OVT004967-004968,
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`290-IPB-OVT005413-005414,
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`290-IPB-
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`OVT007874-007904, 290-IPB-OVT007919-008068.
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`6.
`
`Attached as Exhibit E is a true and correct copy of Godo’s Second
`
`Amended/Supplemental Objections and Responses to OmniVision’s First Set of Interrogatories
`
`(Nos. 1-16), dated May 4, 2018. Here, at page 40, Godo has amended its previous responses to
`
`Interrogatory No. 15, including by removing the citation to twelve previously-relied-upon
`
`LIU DECLARATION IN SUPPORT OF
`OMNIVISION’S DISCOVERY LETTER
`CASE NO. 1:16-cv-00290-MN
`
`
`
`Case 1:16-cv-00290-MN Document 131 Filed 11/28/18 Page 3 of 4 PageID #: 3150
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`documents and adding a citation to a different document, 290-IPB-OVT012949-012995. Godo
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`further states that ‘IP Bridge does not maintain records related to the Asserted Patents by
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`“apparatus, product, device, process, method, act, or other instrumentality that practices at least
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`one asserted claim of any of the Asserted Patents” or “gross revenue…on a quarterly basis.’”
`
`7.
`
`Attached as Exhibit R is a true and correct copy of Exhibit 5 to Godo’s Initial
`
`Infringement Contentions for United States Patent 6,794,677, OV5650 (OmniBSI), served on
`
`January 22, 2018.
`
`8.
`
`Attached as Exhibit S is a true and correct copy of a Friday, November 2, 2018
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`email from Godo’s Counsel (Chijioke Offor) to OmniVision’s Counsel, including me by virtue
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`of my inclusion in the “WSGR – OVT/IP Bridge” email list. The email is the first notice from
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`Godo of a Huawei deposition, and the first notice that it was scheduled for the following
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`Tuesday, November 6, 2018.
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`9.
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`Attached as Exhibit T is a true and correct copy of email correspondence,
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`including a November 5, 2018 email between Godo’s Counsel (Chijioke Offor) and
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`OmniVision’s Counsel (Lisa Zang) that was forwarded to me by Ms. Zang by virtue of my
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`inclusion in the “WSGR – OVT/IP Bridge” email list. The email relates to the rescheduling of
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`the Huawei deposition.
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`10.
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`Attached as Exhibit U is a true and correct copy of an email chain between
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`OmniVision’s Counsel (including Lisa Zang) and Godo’s Counsel (including Sam Joyner) that I
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`received by virtue of my inclusion in the “WSGR – OVT/IP Bridge” email list. The emails
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`related to OmniVision’s objection to the Huawei deposition, dated between November 6-8, 2018.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`LIU DECLARATION IN SUPPORT OF
`OMNIVISION’S DISCOVERY LETTER
`CASE NO. 1:16-cv-00290-MN
`
`-2-
`
`
`
`Case 1:16-cv-00290-MN Document 131 Filed 11/28/18 Page 4 of 4 PageID #: 3151
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`Executed at Austin, Texas on November 28, 2018.
`
`/s/ Diyang Liu
`Diyang Liu
`
`LIU DECLARATION IN SUPPORT OF
`OMNIVISION’S DISCOVERY LETTER
`CASE NO. 1:16-cv-00290-MN
`
`-3-
`
`