`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`APPLE INC.
`Petitioner,
`
`v.
`
`MAXELL, LTD.,
`Patent Owner
`_______________
`
`Case: IPR2020-00408
`
`U.S. Patent No. 6,430,498
`_______________
`
`DECLARATION OF TIFFANY A. MILLER
`
`Apple v. Maxell
`IPR2020-00408
`Maxell Ex. 2016
`
`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
`IPR2020-00408
`Maxell Ex. 2016
`
`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 were served on April 7, 2020.
`
`I declare that all statements made herein of my knowledge are true, and that
`
`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 12, 2020
`
`
`
`__________________________________
`
`Tiffany A. Miller
`
`Apple v. Maxell
`IPR2020-00408
`Maxell Ex. 2016
`
`Page 3 of 3
`
`
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