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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF NEW JERSEY
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`OANDA CORPORATION,
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`Plaintiff,
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`v.
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`GAIN CAPITAL HOLDINGS, INC. and
`GAIN CAPITAL GROUP, LLC,
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`Defendants.
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`Case No. 3:20-cv-05784-ZBQ-DEA
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`DECLARATION OF NATALIE J. MORGAN IN SUPPORT OF DEFENDANTS’
`OPPOSITION TO OANDA’S MOTION TO AMEND INFRINGEMENT CONTENTIONS
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`I, Natalie J. Morgan, declare as follows:
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`1.
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`I am an attorney at the law firm of Wilson Sonsini Goodrich & Rosati, P.C., and counsel
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`of record for defendants Gain Capital Holdings, Inc. and Gain Capital Group, LLC (collectively,
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`“GAIN” or “Defendants”). I have personal knowledge of the facts set forth in this declaration, and if
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`called as a witness, I could and would testify competently thereto.
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`2.
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`Attached hereto as Exhibit A is a true and correct copy of Plaintiff’s proposed
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`Amended Infringement Contentions for U.S. Patent No. 7,146,336, with highlights as described in
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`GAIN’s motion.
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`3.
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`Attached hereto as Exhibit B is a true and correct copy of Plaintiff’s proposed
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`Amended Infringement Contentions for U.S. Patent No. 8,392,311, with highlights as described in
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`GAIN’s motion.
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`4.
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`Attached hereto as Exhibit C is a true and correct copy of Defendants Gain Capital
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`Holdings, Inc. and Gain Capital Group, LLC’s Rule 26(a) Initial Disclosures, dated June 16, 2021.
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`Case 3:20-cv-05784-ZNQ-DEA Document 190 Filed 06/30/23 Page 2 of 3 PageID: 6731
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`5.
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`Attached hereto as Exhibit D is a true and correct copy of Defendant Gain Capital
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`Holdings, Inc.’s Second Supplemental Responses to Plaintiff’s First Set of Requests for Production
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`(Nos. 1-32), dated November 1, 2021.
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`6.
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`Attached hereto as Exhibit E is a true and correct copy of a document bearing Bates
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`numbers GAIN_00353438 – GAIN_0353440,
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`titled PRICING/G2-Pricing-Architecture_
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`37226701.html.
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`7.
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`Attached hereto as Exhibit F is a true and correct copy of a document bearing Bates
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`numbers GAIN_0011524 - GAIN_0011594.
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`8.
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`Attached hereto as Exhibit G is a true and correct copy of a document bearing Bates
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`numbers GAIN_0011595 – GAIN_0011609.
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`9.
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`Attached hereto as Exhibit H is a true and correct copy of the Declaration of Shaun
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`Paisley in Support of Plaintiff Oanda Corporation’s Motion to Amend Infringement Contentions under
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`Local Patent Rule 3.7 (D.I. 171-1), with exemplary highlights identifying the statements that constitute
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`attorney argument. That portions of Exhibit H are not highlighted does not mean that GAIN agrees
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`with what may be asserted as “facts.”
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`10.
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`Attached hereto as Exhibit I is a true and correct copy of the errata for the deposition
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`of David Leach, dated November 18, 2022.
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`11.
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`Attached hereto as Exhibit J is a true and correct copy of a document bearing Bates
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`numbers GAIN_0021033 – GAIN_0021036, marked as Exhibit 7 to the Deposition of David Leach.
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`12.
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`Attached hereto as Exhibit K is a true and correct copy of a document bearing Bates
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`numbers GAIN_0021345 – GAIN_0021347, marked as Exhibit 8 to the Deposition of David Leach.
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`-2-
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`Case 3:20-cv-05784-ZNQ-DEA Document 190 Filed 06/30/23 Page 3 of 3 PageID: 6732
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`13.
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`Attached hereto as Exhibit L is a true and correct copy of a document bearing Bates
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`number GAIN_0021975, marked as Exhibit 9 to the Deposition of David Leach.
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`14.
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`Attached hereto as Exhibit M is a true and correct copy of a document bearing Bates
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`numbers GAIN_0022054 – GAIN_0022056, marked as Exhibit 10 to the Deposition of David Leach.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed in San Diego,
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`California on this 2nd day of June, 2023.
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`By:
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`Natalie J. Morgan
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`-3-
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