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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 22-311-WCB
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`JURY TRIAL DEMANDED
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`))))))))))
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`IMPOSSIBLE FOODS INC.,
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`MOTIF FOODWORKS, INC. and
`GINKGO BIOWORKS, INC.,
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`Plaintiff,
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`v.
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`Defendants.
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`DECLARATION OF KRISTINA M. HANSON
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`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Andrew M. Moshos (#6685)
`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
`amoshos@potteranderson.com
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`Attorneys for Plaintiff Impossible Foods Inc.
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`OF COUNSEL:
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`Wendy L. Devine
`Kristina M. Hanson
`Shannon P. Gillespie McComb
`Jessica Ramsey
`Joyce K. Yao
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`One Market Plaza
`Spear Tower, Suite 3300
`San Francisco, CA 94105
`Tel: (415) 947-2000
`
`Matthew R. Reed
`Jeffrey Nall
`Quincy Rush
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`650 Page Mill Road
`Palo Alto, CA 94304
`Tel: (650) 493-9300
`
`Lori P. Westin
`Natalie J. Morgan
`WILSON SONSINI GOODRICH & ROSATI, P.C.
`12235 El Camino Real
`San Diego, CA 92130
`Tel: (858) 350-2300
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`Michael T. Rosato
`Sonja R. Gerrard
`WILSON SONSINI GOODRICH & ROSATI, P.C.
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`PUBLIC VERSION
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`Case 1:22-cv-00311-WCB Document 483 Filed 04/18/24 Page 2 of 4 PageID #: 27978
`
`701 Fifth Avenue, Suite 5100
`Seattle, WA 98104
`Tel: (206) 883-2529
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`Matthew Macdonald
`WILSON SONSINI GOODRICH &
`ROSATI, P.C.
`953 East Third Street, Suite 100
`Los Angeles, CA 90013
`Tel: (323) 210-2953
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`Dated: April 11, 2024
`11442920 / 20200.00002
`Public Version Dated: April 18, 2024
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`
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`Case 1:22-cv-00311-WCB Document 483 Filed 04/18/24 Page 3 of 4 PageID #: 27979
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`I, Kristina M. Hanson, hereby declare as follows:
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`1.
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`I am an attorney at Wilson Sonsini Goodrich & Rosati P.C., counsel for plaintiff
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`Impossible Foods Inc. (“Impossible”).
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`2.
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`I am fully familiar with the matters set forth herein, and submit this declaration in
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`support of Plaintiff Impossible Foods Inc.’s Responsive Letter Brief Regarding Ginkgo Bioworks
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`Inc.’s Motion to Compel Slack Messages.
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`3.
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`I have been in correspondence with Impossible’s data collection and production
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`vendor, Consilio LLC (“Consilio”).
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`4.
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`As of April 10, 2024, Consilio completed processing of the Slack data
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`corresponding
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`to
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` This data has yielded
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`. Exhibit J to Plaintiff Impossible’s
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`Responsive Letter Brief is a true and correct copy of a spreadsheet I received on April 10, 2024
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`from Consilio regarding the progress of processing the Slack data.
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`5.
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`From correspondence with Consilio, I understand that the size of the data from the
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`custodian and channels processed to date as reflected in Exhibit J was
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`.
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`6.
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`Impossible has produced over 60,000 documents in this litigation, more than 15,000
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`of which resulted from additional discovery efforts related to Ginkgo’s requests in the Yeast
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`Patents Case.
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`7.
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`When searching for the term “Slack,” the search results in 339 documents,
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`including some documents which are duplicative, such as repetitive email chains.
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`8.
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`I have met and conferred on at least three occasions with counsel for Ginkgo
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`regarding Slack production, including on December 12, 2023, February 1, 2024, and February 14,
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`Case 1:22-cv-00311-WCB Document 483 Filed 04/18/24 Page 4 of 4 PageID #: 27980
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`2024. On at least one of the conferences, I informed counsel for Ginkgo that Impossible would
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`not be amenable to Ginkgo’s offer of a 30(b)(6) deposition or an onsite inspection.
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`I declare under penalty of perjury that, to the best of my knowledge, the foregoing
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`statements are true and correct. Executed this 11th day of April, 2024, in San Francisco,
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`California.
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`___________________________
`Kristina M. Hanson
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`2
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