`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`APPLE INC.
`Petitioner,
`
`v.
`
`MAXELL, LTD.,
`Patent Owner
`_______________
`
`Case: IPR2020-00203
`
`U.S. Patent No. 6,408,193
`_______________
`
`DECLARATION OF TIFFANY A. MILLER
`
`
`
`
`
`
`
`
`Apple v. Maxell
`IPR2020-00203
`Maxell Ex. 2027
`
`Page 1 of 3
`
`
`
`I, Tiffany A. Miller, hereby declare and state as follows:
`
`
`
`1.
`
`I am an attorney at Mayer Brown LLP, and counsel for Plaintiff Maxell,
`
`Ltd. (“Maxell”) in Maxell, Ltd. v. Apple Inc., No. 5:19-cv-00036-RWS (E.D. Tex)
`
`(“District Court Action”). I am over 21 years of age and otherwise competent to
`
`make this Declaration. I make this Declaration based on facts and matters within my
`
`own knowledge and on information provided to me by others, and, if called to do so,
`
`I could and would testify competently as to the same.
`
`2.
`
`Fact discovery in the District Court Action closed on March 31, 2020,
`
`with the exception of certain depositions, postponed due to the current pandemic,
`
`that are now complete.
`
`3.
`
`During fact discovery in the District Court Action, Maxell and Apple
`
`collectively produced nearly two million pages of documents. The parties also
`
`collectively took more than 35 depositions.
`
`4.
`
`During fact discovery in the District Court Action, the parties
`
`collectively filed roughly twenty motions, served fifty interrogatories, and served
`
`one hundred twenty requests for admission.
`
`5.
`
`During fact discovery in the District Court Action, Maxell and Apple
`
`have collectively served over thirty third-party subpoenas.
`
`Apple v. Maxell
`IPR2020-00203
`Maxell Ex. 2027
`
`Page 2 of 3
`
`
`
`6.
`
`Expert discovery is currently underway. To date, Maxell’s experts have
`
`already spent nearly six hundred hours reviewing source code produced by Apple.
`
`Opening expert reports will be served on May 7, 2020.
`
` declare that all statements made herein of my knowledge are true, and that
`
` I
`
`all statements made on information and belief are believed to be true, and 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 of Title
`
`18 of the United States Code.
`
`
`
`Dated: May 1, 2020
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`__________________________________
`
`
`
`Tiffany A. Miller
`
`Apple v. Maxell
`IPR2020-00203
`Maxell Ex. 2027
`
`Page 3 of 3
`
`
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
