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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`GODO KAISHA IP BRIDGE 1,
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`Plaintiff,
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`v.
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`OMNIVISION TECHNOLOGIES, INC., §
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`Defendant.
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`DECLARATION OF JENNIFER M. RYNELL
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`CIVIL ACTION NO. 1:16-cv-00290-SLR
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`JURY TRIAL DEMANDED
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`I, Jennifer M. Rynell, declare as follows:
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`1.
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`I am a counsel of record for Godo Kaisha IP Bridge 1, L.P. (“IP Bridge”), the
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`plaintiff in this lawsuit. The facts stated below are within my personal knowledge.
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`2.
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`On June 15, 2016, IP Bridge served venue discovery upon defendant OmniVision
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`Technologies, Inc. (“OmniVision”).
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`3.
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`On June 30, 2016, OmniVision served its responses to IP Bridge’s venue
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`discovery.
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`4.
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`Attached hereto as Exhibit A is OmniVision’s Objections and Responses to IP
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`Bridge’s Requests for Admission.
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`5.
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`Attached hereto as Exhibit B is OmniVision’s Objections and Responses to IP
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`Bridge’s Interrogatories.
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`6.
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`Attached hereto as Exhibit C is OmniVision’s Objections and Responses to IP
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`Bridge’s Requests for Production.
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`7.
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`Attached hereto as Exhibit D is OmniVision’s 2015 Annual Report, which is
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`available on the internet at
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`Case 1:16-cv-00290-MN Document 23 Filed 08/10/16 Page 2 of 2 PageID #: 797
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`http://www.ovt.com/uploads/annualreport/OmniVision%202015%20Annual%20Report.pdf and
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`was last accessed August 9, 2016.
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`8.
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`Attached hereto as Exhibit E is the PriceWaterhouseCooper 2016 Patent
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`Litigation Study, which is available on the internet at https://www.pwc.com/us/en/forensic-
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`services/publications/assets/2016-pwc-patent-litigation-study.pdf and was last accessed on
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`August 9, 2016.
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`9.
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`Attached hereto as Exhibit F is the webpage http://ipbridge.co.jp/en/service,
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`which was last accessed on August 10, 2016.
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`10.
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`Attached hereto as Exhibit G is the webpage http://ipbridge.co.jp/en/company,
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`which was last accessed on August 10, 2016.
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`11.
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`Attached hereto as Exhibit H is the webpage www.xe.com, which provides real-
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`time updates on foreign exchange rates and was last accessed on August 10, 2016.
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`12.
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`Attached here to as Exhibit I are pages from OmniVision’s production Bates-
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`labeled OMNI VENUE 000146 – OMNI VENUE 000156.
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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, and that this declaration was executed on this 10th day of August,
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`2016.
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`/s Jennifer M. Rynell
`Jennifer M. Rynell
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