`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF GEORGIA
`ATLANTA DIVISION
`
`SIPCO, LLC, et al.,
`
`v.
`
`Plaintiffs,
`
`EMERSON ELECTRIC CO., et al.,
`
`Defendants.
`
`Civil Action No: 1:16-cv-02690-AT
`
`DECLARATION OF JAMES C. HALL IN SUPPORT OF PLAINTIFFS’
`OPPOSITION TO DEFENDANTS’ MOTION FOR LEAVE TO SERVE
`AMENDED SUPPLEMENTAL INVALIDITY CONTENTIONS
`
`I, James C. Hall, state as follows:
`
`1.
`
`I am a competent adult over 18 years of age able to testify as to
`
`personal knowledge. The facts in this declaration are true and correct to the best of
`
`my knowledge, information, and belief, and I am competent to testify to them if
`
`called upon to do so.
`
`2.
`
`Attached hereto as Exhibit A is a true and correct copy of a Complaint
`
`for Declaratory Judgment of Patent Non Infringement and Invalidity, dated July
`
`31, 2013.
`
`
`
`Case 1:16-cv-02690-AT Document 121-1 Filed 08/05/16 Page 2 of 3
`
`3.
`
`Attached hereto as Exhibit B is a true and correct copy of a Complaint
`
`for Declaratory Judgment of Patent Non Infringement and Invalidity, dated January
`
`30, 2015.
`
`4.
`
`Attached hereto as Exhibit C is a true and correct copy of Plaintiffs’
`
`First Set of Joint Invalidity Contentions, dated October 26, 2015.
`
`5.
`
`Attached hereto as Exhibit D is a true and correct copy of Plaintiffs’
`
`Joint Invalidity Contentions, dated December 23, 2015.
`
`6.
`
`Attached hereto as Exhibit E is a true and correct copy of Defendants’
`
`Joint Invalidity Contentions, dated May 16, 2016.
`
`7.
`
`Attached hereto as Exhibit F is a true and correct copy of Defendants’
`
`Supplemental Joint Invalidity Contentions, dated June 13, 2016.
`
`8.
`
`Attached hereto as Exhibit G is a true and correct copy of a
`
`Memorandum Opinion and Order dated March 28, 2016 in the case of Imperium IP
`
`Holdings (Cayman), Ltd. v. Samsung Electronics Co., Ltd., No. 4:14-cv-371, 2016
`
`WL 3854700 (E.D. Texas March 28, 2016).
`
`9.
`
`Attached hereto as Exhibit H is a true and correct copy of a
`
`Memorandum Opinion and Order dated March 30, 2012 in the case of Patent
`
`Harbor, LLC v. Audiovox Corp., No. 6:10-cv-00361 LED-JDL, No. 6:10-cv-00436
`
`2
`
`
`
`Case 1:16-cv-02690-AT Document 121-1 Filed 08/05/16 Page 3 of 3
`
`LED-JDL, No. 6:10-cv-00607 LED JDL, 2012 WL 12840341 (E.D. Texas, March
`
`30, 2012).
`
`10. Attached hereto as Exhibit I is a true and correct copy of an Order
`
`dated August 11, 2011 in the case of LML Patent Corp. v. JPMorgan Chase & Co.,
`
`No. 2:08-cv-448, 2011 WL 5158285 (E.D. Texas, August 11, 2011).
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`DATED: August 5, 2016
`
`3240583.1
`
`/s/ James C. Hall
`James C. Hall
`
`3
`
`
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