`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`GUARDANT HEALTH, INC.,
`
`Plaintiff,
`
`v.
`
`FOUNDATION MEDICINE, INC.,
`
`Defendant.
`
`C.A. No. 20-cv-1580-LPS
`
`FILED UNDER SEAL
`
`DECLARATION OF JUSTIN CONSTANT IN SUPPORT OF GUARDANT’S REPLY IN
`SUPPORT OF ITS MOTION FOR PRELIMINARY INJUNCTION
`
`
`
`Case 1:20-cv-01580-LPS Document 56 Filed 04/21/21 Page 2 of 3 PageID #: 12029
`
`
`
`1.
`I am an attorney with the law firm of Weil, Gotshal & Manges LLP, counsel of
`record for Guardant Health, Inc. (“Guardant”) in the above-captioned matter. I submit this
`declaration based on personal knowledge and following a reasonable investigation. If called upon
`as a witness, I could competently testify to the truth of each statement herein.
`
`2.
`Attached as Exhibit 1 is a true and correct copy of an excerpt of the deposition
`transcript of Gary Benson, dated March 15, 2021.
`
`3.
`Attached as Exhibit 2 is a true and correct copy of an excerpt of the deposition
`transcript of Stacey Gabriel, Ph.D, dated on March 1, 2021.
`
`4.
`Attached as Exhibit 3 is true and correct copy of an excerpt of the deposition
`transcript of Gregory Cooper, Ph.D, dated on January 1, 2021
`
`5.
`Attached as Exhibit 4 is a true and correct copy of an excerpt of the File History for
`U.S. Patent No. 10,704,085.
`
`6.
`
`Attached as Exhibit 5 is a true and correct copy of U.S. Patent No. 9,902,992.
`
`7.
`Attached as Exhibit 6 is a true and correct copy of an excerpt of the deposition
`transcript of Dr. Neal Shore, dated on March 10, 2021.
`
`8.
`Attached as Exhibit 7 is a true and correct copy of an excerpt of the deposition
`transcript of Elizabeth Mansfield, dated on March 17, 2021.
`
`9.
`Attached as Exhibit 8 is a true and correct copy of an excerpt of the deposition
`transcript of Mark Kennedy, dated on April 12, 2019.
`
`I declare under the penalty of perjury under the laws of the United States of America that
`the foregoing is true and correct.
`
`
`
`
`
`
`Case 1:20-cv-01580-LPS Document 56 Filed 04/21/21 Page 3 of 3 PageID #: 12030
`
`Executed on March 29, 2021 at Houston, Texas.
`
`
`/s/ Justin Constant
`Justin Constant
`
`
`
`
`
`
`
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`
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