Case 2:17-cv-00513-JRG Document 175-1 Filed 08/14/18 Page 1 of 4 PageID #: 7247
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff,
`
`v.
`
`HUAWEI DEVICE USA INC., HUAWEI
`DEVICE CO., LTD. AND HUAWEI DEVICE
`(DONGGUAN) CO., LTD.,
`HTC CORPORATION,
`LG ELECTRONICS INC.,
`APPLE INC.,
`ZTE CORPORATION, ZTE (USA), INC.,
`AND ZTE (TX), INC.,
`
`
`
`Defendants.
`
`
`
`
`
`
`
`
`Civil Action No. 2:17-CV-513-JRG
`(Lead Case)
`
`Member Cases:
`Civil Action No. 2:17-CV-514-JRG
`Civil Action No. 2:17-CV-515-JRG
`Civil Action No. 2:17-CV-516-JRG
`Civil Action No. 2:17-CV-517-JRG
`
`JURY TRIAL DEMANDED
`
`DECLARATION OF KERRI-ANN LIMBEEK IN SUPPORT OF
`DEFENDANTS’ RESPONSIVE CLAIM CONSTRUCTION BRIEF
`
`
`I, Kerri-Ann Limbeek, declare that:
`
`1.
`
`I am an associate with the law firm of Desmarais LLP, counsel of record for
`
`Defendant Apple Inc. (“Apple”) in the above-captioned matter, and I am admitted pro hac vice to
`
`this Court. I submit this declaration based on personal knowledge, and if called upon as a witness,
`
`I could competently testify to the truth of each statement herein.
`
`2.
`
`I make this Declaration in support of Defendants Responsive Claim Construction
`
`Brief.
`
`3.
`
`Attached hereto as Exhibit 1 is a true and correct copy of U.S. Patent No. 9,467,838,
`
`bearing production numbers AGISTX_00005926-AGISTX_00005947.
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`
`AGIS SOFTWARE DEVELOPMENT LLC,
`
`Plaintiff,
`
`v.
`
`HUAWEI DEVICE USA INC., HUAWEI
`DEVICE CO., LTD. AND HUAWEI DEVICE
`(DONGGUAN) CO., LTD.,
`HTC CORPORATION,
`LG ELECTRONICS INC.,
`APPLE INC.,
`ZTE CORPORATION, ZTE (USA), INC.,
`AND ZTE (TX), INC.,
`
`
`
`Defendants.
`
`
`
`
`
`
`
`
`Civil Action No. 2:17-CV-513-JRG
`(Lead Case)
`
`Member Cases:
`Civil Action No. 2:17-CV-514-JRG
`Civil Action No. 2:17-CV-515-JRG
`Civil Action No. 2:17-CV-516-JRG
`Civil Action No. 2:17-CV-517-JRG
`
`JURY TRIAL DEMANDED
`
`DECLARATION OF KERRI-ANN LIMBEEK IN SUPPORT OF
`DEFENDANTS’ RESPONSIVE CLAIM CONSTRUCTION BRIEF
`
`
`I, Kerri-Ann Limbeek, declare that:
`
`1.
`
`I am an associate with the law firm of Desmarais LLP, counsel of record for
`
`Defendant Apple Inc. (“Apple”) in the above-captioned matter, and I am admitted pro hac vice to
`
`this Court. I submit this declaration based on personal knowledge, and if called upon as a witness,
`
`I could competently testify to the truth of each statement herein.
`
`2.
`
`I make this Declaration in support of Defendants Responsive Claim Construction
`
`Brief.
`
`3.
`
`Attached hereto as Exhibit 1 is a true and correct copy of U.S. Patent No. 9,467,838,
`
`bearing production numbers AGISTX_00005926-AGISTX_00005947.
`
`
`
`Case 2:17-cv-00513-JRG Document 175-1 Filed 08/14/18 Page 2 of 4 PageID #: 7248
`
`4.
`
`Attached hereto as Exhibit 2 is a true and correct copy of U.S. Patent No. 8,213,970,
`
`bearing production numbers AGISTX_00005824-AGISTX_00005836.
`
`5.
`
`Attached hereto as Exhibit 3 is a true and correct copy of excerpts from The Oxford
`
`American Dictionary of Current English, Oxford University Press (1999).
`
`6.
`
`Attached hereto as Exhibit 4 is a true and correct copy of excerpts from Webster’s
`
`New World Dictionary of Computer Terms, Bryan Pfafftnberger, Ph.D. (8 ed. 2000).
`
`7.
`
`Attached hereto as Exhibit 5 is a true and correct copy of an October 27, 2010 office
`
`action in the prosecution history of U.S. Patent Application Serial No. 11/615,472, which issued
`
`as U.S. Patent No. 8,126,441, bearing production numbers AGISTX_00000558-
`
`AGISTX_00000582.
`
`8.
`
`Attached hereto as Exhibit 6 is a true and correct copy of a February 23, 2011
`
`Response and Amendment to an office action in the prosecution history of U.S. Patent Application
`
`Serial No. 11/615,472, which issued as U.S. Patent No. 8,126,441, bearing production numbers
`
`AGISTX_00000537- AGISTX_00000557.
`
`9.
`
`Attached hereto as Exhibit 7 is a true and correct copy of an August 13, 2013 office
`
`action in the prosecution history of U.S. Patent Application Serial No. 14/633,804, which issued
`
`as U.S. Patent No. 9,445,251, bearing production numbers AGISTX_00004319-
`
`AGISTX_00004346.
`
`10.
`
`Attached hereto as Exhibit 8 is a true and correct copy of a November 13, 2015
`
`Response and Amendment to an office action in the prosecution history of U.S. Patent Application
`
`Serial No. 14/633,804, which issued as U.S. Patent No. 9,445,251, bearing production numbers
`
`AGISTX_00004287- AGISTX_00004314.
`
`
`
`2
`
`
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`Case 2:17-cv-00513-JRG Document 175-1 Filed 08/14/18 Page 3 of 4 PageID #: 7249
`
`11.
`
`Attached hereto as Exhibit 9 is a true and correct copy of a December 10, 2015
`
`office action in the prosecution history of U.S. Patent Application Serial No. 14/633,804, which
`
`issued as U.S. Patent No. 9,445,251, bearing production numbers AGISTX_00004261-
`
`AGISTX_00004285.
`
`12.
`
`Attached hereto as Exhibit 10 is a true and correct copy of a February 29, 2016
`
`Supplemental Response to an office action in the prosecution history of U.S. Patent Application
`
`Serial No. 14/695,233, which issued as U.S. Patent No. 9,408,055, bearing production numbers
`
`AGISTX_00004939- AGISTX_00004960.
`
`13.
`
`Attached hereto as Exhibit 11 is a true and correct copy of a March 24, 2016 office
`
`action in the prosecution history of U.S. Patent Application Serial No. 14/695,233, which issued
`
`as U.S. Patent No. 9,408,055, bearing production numbers AGISTX_00004916-
`
`AGISTX_00004934.
`
`14.
`
`Attached hereto as Exhibit 12 is a true and correct copy of an excerpt of Microsoft
`
`Computer Dictionary, Microsoft Press (5 ed. 2002), bearing production numbers DEFS-AGIS-
`
`CC_000333- DEFS-AGIS-CC_000336.
`
`15.
`
`Attached hereto as Exhibit 13 is a true and correct copy of a December 17, 2010
`
`Response and Amendment to an office action in the prosecution history of U.S. Patent Application
`
`Serial No. 2/324,122, which issued as U.S. Patent No. 8,213,970, bearing production numbers
`
`AGISTX_00001268- AGISTX_00001282.
`
`16.
`
`Attached hereto as Exhibit 14 is a true and correct copy of a September 9, 2011
`
`Response and Amendment to an office action in the prosecution history of U.S. Patent Application
`
`Serial No. 2/324,122, which issued as U.S. Patent No. 8,213,970, bearing production numbers
`
`AGISTX_00001224- AGISTX_00001243.
`
`
`
`3
`
`
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`Case 2:17-cv-00513-JRG Document 175-1 Filed 08/14/18 Page 4 of 4 PageID #: 7250
`
`17.
`
`Attached hereto as Exhibit 15 is a true and correct copy of U.S. Patent No.
`
`7,031,728, bearing production numbers AGISTX_00005688-AGISTX_00005700.
`
`18.
`
`Attached hereto as Exhibit 16 is a true and correct copy of U.S. Patent No.
`
`7,630,724, bearing production numbers AGISTX_00005701-AGISTX_00005719.
`
`19.
`
`Attached hereto as Exhibit 17 is a true and correct copy of U.S. Patent No.
`
`9,408,055, bearing production numbers AGISTX_00005885-AGISTX_00005905.
`
`20.
`
`Attached hereto as Exhibit 18 is a true and correct copy of U.S. Patent No.
`
`9,445,251, bearing production numbers AGISTX_00005906-AGISTX_00005925.
`
`21.
`
`Attached hereto as Exhibit 19 is a true and correct copy of U.S. Patent Publication
`
`No. 2004/0148090 A1 to Melen.
`
`22.
`
`Attached hereto as Exhibit 20 is a true and correct copy of an excerpt of 3G TS
`
`23.040 Technical Specification V1.0.0, 3rd Generation Partnership Project (1999-05), bearing
`
`production
`
`numbers DEFS-AGIS-CC_000001-DEFS-AGIS-CC_000002, DEFS-AGIS-
`
`CC_000006.
`
`23.
`
`Attached hereto as Exhibit 21 is a true and correct copy of an excerpt of Microsoft
`
`Computer Dictionary, Microsoft Press (5 ed. 2002), bearing production numbers DEFS-AGIS-
`
`CC_000353- DEFS-AGIS-CC_000355.
`
`I declare under penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct.
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`Executed on August 13, 2018, in New York, NY.
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` /s/ Kerri-Ann Limbeek___
` Kerri-Ann Limbeek
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`4
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