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`Defendant.
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`Plaintiff,
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`UNILOC 2017 LLC,
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`v.
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`PAYCHEX, INC.,
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`UNILOC 2017 LLC,
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`
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`v.
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`ATHENAHEALTH, INC.,
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`
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`Case 1:19-cv-11278-RGS Document 42 Filed 02/19/20 Page 1 of 2
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`UNITED STATES DISTRICT COURT
`DISTRICT OF MASSACHUSETTS
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`Civil Action No. 1:19-cv-11272-RGS
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`Civil Action No. 1:19-cv-11278-RGS
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`Defendant.
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`UNOPPOSED MOTION OF PLAINTIFF TO SUBSTITUTE CORRECTED
`DECLARATION
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`Plaintiff Uniloc 2017, LLC had previously filed a Declaration of Dr. Michael Shamos,
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`Dkt. No. 26-1.1 After the filing, Dr. Shamos discovered a “cut and paste error” in a section of the
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`Declaration, at paragraph numbers 75-86. He then prepared the Corrected Declaration attached to
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`the Gannon Declaration as Exhibit A, which is identical to the original Declaration, except that
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`paragraphs 75-86 have been rewritten to correct the error.
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`A copy of this Corrected Declaration was provided to Defendants on February 9, the day
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`before the deposition of Dr. Shamos. At his deposition, Dr. Shamos described how the error
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`occurred and what he did to correct it. See Ex. B to Gannon Declaration.
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`1 Citation is to the docket in 1:19-cv-11272-RGS.
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`Case 1:19-cv-11278-RGS Document 42 Filed 02/19/20 Page 2 of 2
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`Defendants have informed Plaintiff they do not oppose substitution of the attached
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`Corrected Declaration for the original.
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`Dated: February 19, 2020.
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`/s/ Kevin Gannon
`Paul J. Hayes
`James J. Foster
`Kevin Gannon
`PRINCE LOBEL TYE LLP
`One International Place, Suite 3700
`Boston, MA 02110
`Tel: (617) 456-8000
`Email: phayes@princelobel.com
`Email: jfoster@princelobel.com
`Email: kgannon@princelobel.com
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`ATTORNEYS FOR THE PLAINTIFF
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`CERTIFICATE OF SERVICE
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`I certify that all counsel of record who have consented to electronic service are being
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`served with a copy of this document via the Court’s CM/ECF system.
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`/s/ Kevin Gannon
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