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