`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`
`INTEL CORP. and CAVIUM, INC.,
`Petitioner
`
`v.
`
`ALACRITECH, INC.
`Patent Owner
`
`________________________
`
`Case Nos.
` IPR2017-01391 (U.S. Patent No. 7,237,036)1
`IPR2017-01392 (U.S. Patent No. 7,337,241)
`IPR2017-01393 (U.S. Patent No. 9,055,104)
`IPR2017-01405 (U.S. Patent No. 7,124,205)
`IPR2017-01406 (U.S. Patent No. 7,673,072)
`IPR2017-01409 (U.S. Patent No. 8,131,880)
`IPR2017-01410 (U.S. Patent No. 8,131,880)
`
`________________________
`
`DECLARATION OF GARLAND STEPHENS IN SUPPORT OF
`PETITONER’S OPPOSITION TO PATENT OWNER’S MOTION FOR
`ADDITIONAL DISCOVERY REGARDING REAL PARTIES-IN-
`INTEREST
`
`
`
`
`
`1 Cavium, Inc., which filed Petitions in Cases: IPR2017-01707, IPR2017-01714,
`IPR2017-01718, IPR2017-01728, IPR2017-01735, IPR2017-01736, IPR2017-
`01737, has been joined as a petitioner in the listed proceedings.
`
`
`INTEL EX.1110.001
`
`
`
`I, Garland Stephens, declare:
`
`1. I am an attorney with the law firm of Weil, Gotshal & Manges LLP
`
`(“Weil”), counsel for Intel Corporation (“Intel”).
`
`2. I have personal knowledge of the matters set forth in this declaration.
`
`If called as a witness, I could and would competently testify as to these matters.
`
`3. I am lead counsel on the following inter partes review petitions:
`
`IPR2017-01391, IPR2017-01392, IPR2017-01393, IPR2017-01405, IPR2017-
`
`01406, IPR2017-01409, and IPR2017-01410 (“Petitions”).
`
`4. I was directed to prepare and file these Petitions solely by in-house
`
`counsel at Intel.
`
`5. I supervised the team that prepared these Petitions. I personally
`
`reviewed, edited, signed and authorized the filing of each of the Petitions. The
`
`only persons who provided any substantive input into, or exercised any control
`
`over, these Petitions were attorneys and staff at Weil, Petitioner Intel’s experts, and
`
`Petitioner Intel’s in-house counsel. No substantive input was solicited or accepted
`
`from any other person or entity. No drafts were shared with any other person or
`
`entity prior to the filing of the Petitions. No other person or entity provided any
`
`direction or exercised any control over the substance or timing of the filing of the
`
`Petitions
`
`1
`
`INTEL EX.1110.002
`
`
`
`6. Weil did not share the substance of the Petitions before the Petitions
`
`were filed with any other person or entity other than those listed in Paragraph 5,
`
`including Dell, Inc., Wistron Corporation, Wiwynn Corporation, SMS InfoComm
`
`Corporation, CenturyLink Communications LLC, Tier 3, Inc., and Savvis
`
`Communications Corp.
`
`(the "Defendants") and
`
`Intervenor Cavium,
`
`Inc.
`
`("Cavium"). Defendants and Cavium, including their counsel, played no role in
`
`preparing or filing of the Petitions and were not provided any drafts of the Petitions
`
`or the Petitions themselves until after the Petitions were filed.
`
`7. Intel is solely responsible for the fees and costs Weil has incurred in
`
`filing the Petitions. No other person or entity has paid or agreed to pay Weil for
`
`any fees or costs for the Petitions.
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information or belief are believed to be true;
`
`and further that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 or Title 18 of the United States Code and that such willful false
`
`statements may jeopardize the results of these proceedings.
`
`January 10, 2018
`
`C
`
`.
`
`2
`
`INTEL EX.1110.003
`
`
`
`
`
`CERTIFICATE OF SERVICE
`I hereby certify that on January 10, 2018, a copy of DECLARATION OF
`
`
`
`GARLAND STEPHENS IN SUPPORT OF PETITONER’S OPPOSITION
`
`TO PATENT OWNER’S MOTION FOR ADDITIONAL DISCOVERY
`
`REGARDING REAL PARTIES-IN-INTEREST was served by filing this
`
`document through the PTAB’s E2E Filing System as well as delivering a copy via
`
`electronic mail upon the following:
`
`James M. Glass
`Registration No. 46,729
`Quinn Emanuel Urquhart & Sullivan LLP
`51 Madison Ave., 22nd Fl.
`New York, NY 10010
`Tel.: (212) 849-7000
`Email: jimglass@quinnemanuel.com
`
`Joseph M. Paunovich
`Registration No. 59,033
`Quinn Emanuel Urquhart & Sullivan LLP
`865 S. Figueroa Street, 10th Fl.
`Los Angeles, CA 90017
`Tel.: (213) 443-3000
`Email: joepaunovich@quinnemanuel.com
`
`Brian E. Mack
`Registration No. 57,189
`Quinn Emanuel Urquhart & Sullivan LLP
`50 California Street, 22nd Fl.
`San Francisco, CA 94111
`Tel.: (415) 875-6600
`Email: brianmack@quinnemanuel.com
`
`3
`
`INTEL EX.1110.004
`
`
`
`Mark Lauer
`Registration No. 36,578
`Silicon Edge Law Group LLP
`7901 Stoneridge Dr., Ste. 528
`Pleasanton, CA 94588
`Tel.: (925) 621-2121
`Email: mark@siliconedgelaw.com
`
`
`
`Dated: January 10, 2018
`
`
`
`
`
`
`
`
`
`/s/ Garland T. Stephens
`Garland T. Stephens
`Reg. No. 37,242
`
`
`
`
`
`4
`
`INTEL EX.1110.005
`
`