`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 16-290-MN
`
`
`
`
`
`)))))))))
`
`GODO KAISHA IP BRIDGE 1,
`
`Plaintiff,
`
`v.
`
`OMNIVISION TECHNOLOGIES, INC.,
`
`Defendant.
`
`DECLARATION OF MICHELLE MILUNOVIC IN SUPPORT OF
`DEFENDANT OMNIVISION TECHNOLOGIES, INC.’S
`REPLY IN SUPPORT OF MOTION FOR REDACTION OF
`TRANSCRIPT OF DECEMBER 7, 2018 DISCOVERY TELECONFERENCE
`
`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: January 23, 2019
`6065160 / 43303
`
`PUBLIC VERSION
`
`Public Version Dated: February 5, 2019
`
`
`
`Case 1:16-cv-00290-MN Document 168 Filed 02/05/19 Page 2 of 3 PageID #: 5204
`Case 1:16-cv-00290-MN Document 168 Filed 02/05/19 Page 2 of 3 PageID #: 5204
`
`1, Michelle Milunovic, declare as follows:
`
`1.
`
`2.
`
`I am a resident of San Jose, California. I am over the age of 18 years.
`
`I submit this declaration in support of Defendant OmniVision Technologies,
`
`Inc.’s (“OmniVision”) Reply in Support of Motion for Redaction of the Transcript of the
`
`December 7, 2018 Discovery Teleconference in the above-referenced action. The matters set
`
`forth herein are based upon my personal knowledge.
`
`3.
`
`I have been working at OmniVision in Santa Clara, California, since 2007, and I
`
`currently hold the position of Vice President of Sales for North America. My office is located at
`
`4275 Burton Drive, Santa Clara. California. As the Vice President of Sales for North America, I
`
`am responsible for managing OmniVision’s sales team for North America.
`
`In this role, I have
`
`overseen customer support.
`
`4.
`
`Information regarding the identity, location, and business role of Don Boe, an
`
`OmniVision customer support representative based in Chicago who works with certain
`
`OmniVision customers; the identity of one of OmniVision’s customers, Motorola Mobility LLC;
`
`and OmniVision’s internal reporting practices regarding its associated customer support services
`
`is confidential to OmniVision.
`
`5.
`
`It is my understanding that OmniVision would be put at a significant competitive
`
`disadvantage if its competitors were provided insight into how it provides customer support to
`
`customers whose identities are confidential, staffs its customer support team, and internally
`
`manages customer support reports, particularly in light of the competitive market for image
`
`sensors.
`
`I declare under penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct.
`
`
`
`Case 1:16-cv-00290-MN Document 168 Filed 02/05/19 Page 3 of 3 PageID #: 5205
`Case 1:16-cv-00290-MN Document 168 Filed 02/05/19 Page 3 of 3 PageID #: 5205
`
`Executed at Santa Clara, California on January 22, 2019.
`
`aflfl’fndwflzé gm,
`
`Michelle
`
`ilunovic
`
`:.
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
