`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`RUBICON COMMUNICATIONS, LP
`Petitioner,
`
`v.
`
`LEGO A/S
`Patent Owner.
`____________
`
`Case IPR2016-01187
`Patent 8,894,066
`
`
`
`
`
`DECLARATION OF ELIZABETH A. ALQUIST IN SUPPORT OF
`PATENT OWNER’S OPPOSITION TO MOTION TO CORRECT
`
`
`
`
`
`
`
`1
`
`
`
`LEGO A/S Ex. 2017
`Rubicon Communications, LP
`v. LEGO A/S
`IPR2016-01187
`
`
`
`
`
`
`
`
`
`I, Elizabeth A. Alquist, declare the following statements upon my solemn
`
`oath:
`
`1.
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`2.
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`3.
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`I am counsel of record for the Patent Owner in this proceeding,
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`admitted pro hac vice, and the related litigation involving the
`
`challenged patent, LEGO System A/S v. Rubicon Communications, LP
`
`dba Smallworks and Smallworks, LLC, No. 3:15-cv-00823 (D. Conn.
`
`filed May 29, 2015) (the “Connecticut litigation”).
`
`I make all statements in this declaration based upon my own personal
`
`knowledge in support of the Patent Owner’s Opposition to the Motion
`
`to Correct.
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`After months of discovery in the Connecticut litigation, the Patent
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`Owner is not fully aware of the Petitioner’s corporate transactions and
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`identity. As a result, the parties have been and continue to be in
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`discovery disputes regarding Rubicon Communications, LP’s
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`corporate transactions and identities. On December 5, 2016, I
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`deposed James W. Thompson in connection with the Connecticut
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`litigation. Mr. Thompson was designated by Rubicon
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`Communications LP and Smallworks LLC as their corporate
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`representative pursuant to Fed. R. Civ. P. 30(b)(6) on, among others,
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`2
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`
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`4.
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`5.
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`6.
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`7.
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`8.
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`the topic of the corporate structure of Petitioner and its related
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`companies.
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`EXHIBIT 2011 is a true and accurate copy of Def.’s Answer,
`
`Defenses, and Countercls., LEGO System A/S v. Rubicon Commc’ns,
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`LP dba Smallworks and Smallworks, LLC, No. 15-823 (D. Conn. July
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`31, 2015).
`
`EXHIBIT 2012 is a true and accurate copy of Corporate Disclosure
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`Statement, No. 15-823 (D. Conn. July 31, 2015) submitted by the
`
`Petitioner.
`
` EXHIBIT 2013 is a true and accurate copy of Def.’s Answer,
`
`Defenses, and Countercls. to Am. Compl., LEGO System A/S v.
`
`Rubicon Commc’ns, LP dba Smallworks and Smallworks, LLC, No.
`
`15-823 (D. Conn. Nov. 5, 2015).
`
`EXHIBIT 2014 is a true and accurate copy of Def.’s Resp. to Pl.’s
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`First Set of Interrogs. in the Connecticut litigation, served on Aug. 27,
`
`2015.
`
`EXHIBIT 2015 is a true and accurate copy of Smallwork’s Markman
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`Br., LEGO System A/S v. Rubicon Commc’ns, LP dba Smallworks and
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`Smallworks, LLC, No. 15-823 (D. Conn. Mar. 25, 2016).
`
`3
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`
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`9.
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`EXHIBIT 2016 is an excerpt of a true and accurate copy of the rough
`
`transcript of Deposition of James W. Thompson taken on December 5,
`
`2016.
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`
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`I hereby declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true;
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`and further that these statements are made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code and that such willful false
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`statements may jeopardize the validity of the application or any patents issued
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`thereon.
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`
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`SIGNED UNDER THE PENALTIES OF PERJURY, THIS 5th DAY OF
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`DECEMBER, 2016
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`
`
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`
`
`
`
`/ Elizabeth A. Alquist /
`
`Elizabeth A. Alquist
`eaalquist@daypitney.com
`Day Pitney LLP
`242 Trumbull Street
`Hartford, CT 06103
`Tel: (860) 275-0137
`Fax: (860) 881-2456
`
`4
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