`Case 1:14-cv-02396—PGG-MHD Document 176-13 Filed 10/01/19 Page 1 of 3
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` EXHIBIT M
`
`EXHIBIT M
`
`
`
`Case 1:14-cv-02396-PGG-MHD Document 176-13 Filed 10/01/19 Page 2 of 3
`
`UNITED STATES DISTRICT COURT
`SOUTHERN DISTRICT OF NEW YORK
`
`NETWORK-1 TECHNOLOGIES, INC.
`
`Plaintiff,
`
`- against -
`
`GOOGLE LLC and YOUTUBE, LLC
`
`Defendants.
`
`14 Civ. 2396 (PGG)
`
`14 Civ. 9558 (PGG)
`
`DECLARATION OF SUMEET P. DANG. ESQ.
`
`I, Sumeet P. Dang, declare as follows:
`
`1.
`
`I am an attorney with Williams & Connolly LLP, counsel for Defendants in the
`
`case captioned above.
`
`2.
`
`In mid-to-late June 2019, counsel for Defendants first became aware of the
`
`FreeAmp/MusicBrainz system as potential prior art to Network-1 ’s patents and undertook an
`
`investigation of that system.
`
`3.
`
`As part of that investigation, I contacted relevant witnesses (some of whom reside
`
`in Europe) and sought documents and source code regarding the system’s operation.
`
`4.
`
`By August 15, 2019, counsel for Defendants had obtained source code sufficient
`
`to confirm, for the first time, how the FreeAmp/MusicBrainz system operated.
`
`5.
`
`Upon receiving that source code, counsel for Defendants promptly reviewed it.
`
`
`
`Case 1:14-cv-02396-PGG-MHD Document 176-13 Filed 10/01/19 Page 3 of 3
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed on September 30, 2019,
`in Washington, D.C.
`
`WILLIAMS & CONNOLLY LLP
`725 Twelfth Street, N.W.
`Washington, D.C. 20005
`(202) 434-5116
`sdang@wc.com
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
