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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
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`Case No. 2:12-cv-02824 JPM tmp
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`JURY DEMAND
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`Case No. 2:12-cv-02825 JPM tmp
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`JURY DEMAND
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`B.E. TECHNOLOGY, L.L.C.,
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`Plaintiff,
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`v.
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`SAMSUNG
`TELECOMMUNICATIONS
`AMERICA, LLC,
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`
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`Defendant.
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`B.E. TECHNOLOGY, L.L.C.,
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`Plaintiff,
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`
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`v.
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`SAMSUNG ELECTRONICS
`AMERICA, INC.,
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`
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`Defendant.
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`DECLARATION OF QUDUS B. OLANIRAN IN SUPPORT OF MEMORANDUM IN
`OPPOSITION TO DEFENDANT’S MOTION TO COMPEL SUPPLEMENTAL
`INFRINGEMENT CONTENTIONS AND STAY CERTAIN DISCOVERY
`OBLIGATIONS
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`I, Qudus B. Olaniran, declare as follows:
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`1.
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`I am an attorney with the law firm of Freitas Tseng & Kaufman LLP, counsel for
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`B.E. Technology, L.L.C. I have personal knowledge of the facts stated in this Declaration and
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`could testify competently to them if asked to do so.
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`2.
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`Attached hereto as Exhibit 1 is a true and correct copy of a letter to C. Kaufman
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`from J. Nelson dated January 18, 2013.
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`
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`Case 2:12-cv-02825-JPM-tmp Document 57-1 Filed 08/09/13 Page 2 of 2 PageID 626
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`3.
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`Attached hereto as Exhibit 2 is a true and correct copy of a letter to J. Nelson
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`from J. Lin dated January 30, 2013.
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`4.
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`Attached hereto as Exhibit 3 is a true and correct copy of an email to J. Lin from
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`J. MacLean dated July 13, 2013.
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`5.
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`Attached hereto as Exhibit 4 is a true and correct copy of an email to R. Pettus
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`from D. Weinberg dated July 17, 2013.
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`6.
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`Attached hereto as Exhibit 5 is a true and correct copy of Multilayer Stretch
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`Cling Film Holdings, Inc. v. MSC Marketing and Tech., Inc., 2:12-cv-02112-JPM-tmp (W.D.
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`Tenn. July 23, 2013), Order Denying Defendant’s Motion to Compel.
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`7.
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`Attached hereto as Exhibit 6 is a true and correct copy of an excerpt of B.E.
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`Technology L.L.C.’s Initial Infringement Contentions and Document Production Accompanying
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`Initial Infringement Contentions dated July 1, 2013.
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`8.
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`Attached hereto as Exhibit 7 is a true and correct copy of an email to J. Raskin
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`from D. Weinberg dated July 23, 2013.
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`9.
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`Attached hereto as Exhibit 8 is a true and correct copy of an email to D.
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`Weinberg from J. Raskin dated July 23, 2013.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Executed this 9th day of August, 2013, at Redwood Shores, California.
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`Qudus B. Olaniran
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