`
`AGIS SOFTWARE DEVELOPMENT LLC,
`Plaintiff,
`
`v.
`T-MOBILE USA, INC. and T-MOBILE US.
`INC.,
`
`LYFT, INC.,
`
`UBER TECHNOLOGIES, INC., d/b/a UER,
`
`Case No. 2:21-cv-00072-JRG
`(MEMBER CASE)
`
`JURY TRIAL DEMANDED
`
`Case No. 2:21-cv-00072-JRG
`(MEMBER CASE)
`
`JURY TRIAL DEMANDED
`
`Case No. 2:21-cv-00072-JRG
`(MEMBER CASE)
`
`JURY TRIAL DEMANDED
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`§
`
`§
`Case No. 2:21-cv-00072-JRG
`§
`(LEAD CASE)
`§
`
`JURY TRIAL DEMANDED
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`WHATSAPP, INC.,
`Defendants.
`
`
`
`DECLARATION OF MIGUEL J. BOMBACH IN SUPPORT OF DEFENDANTS’
`RESPONSIVE CLAIM CONSTRUCTION BRIEF
`
`
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 156-1 Filed 09/28/21 Page 2 of 3 PageID #: 5216
`
`I, Miguel J. Bombach, hereby declare as follows:
`
`1.
`
`I am an attorney at law licensed to practice before the United States District Court
`
`for the Eastern District of Texas. I am an attorney for Defendants T-Mobile USA, Inc. and T-
`
`Mobile US, Inc. (“T-Mobile”). Unless otherwise stated, I have personal knowledge of the
`
`following facts and, if called and sworn as a witness, could and would competently testify
`
`thereto.
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of the Declaration of Dr.
`
`Shashi Shekhar, which was served on attorneys for AGIS on August 17, 2021.
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of the Sept. 21, 2009
`
`Notice of Allowance in the prosecution of the ’724 Patent, App. No. 11/308648.
`
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of the Nov. 12, 2005
`
`Applicant Amendment in the prosecution of the ’728 Patent, App. No. 10/711490.
`
`5.
`
`Attached hereto as Exhibit 4 is a true and correct copy of printouts from
`
`https://www.merriam-webster.com/dictionary/free that I accessed and printed-to-PDF on
`
`September 28, 2021.
`
`6.
`
`Attached hereto as Exhibit 5 is a true and correct copy of printouts from
`
`https://dictionary.cambridge.org/dictionary/english/free that I accessed and printed-to-PDF on
`
`September 28, 2021.
`
`7.
`
`Attached hereto as Exhibit 6 is a true and correct copy of printouts from
`
`https://encyclopedia2.thefreedictionary.com/message that I accessed and printed-to-PDF on
`
`September 28, 2021.
`
`8.
`
`Attached hereto as Exhibit 7 is a true and correct copy of the Sept. 9, 2011
`
`Applicant Amendment in the prosecution of the ’970 Patent, App. No. 12/324122.
`
`1
`
`
`
`Case 2:21-cv-00072-JRG-RSP Document 156-1 Filed 09/28/21 Page 3 of 3 PageID #: 5217
`
`9.
`
`Attached hereto as Exhibit 8 is a true and correct copy of the Dec. 17, 2010
`
`Applicant Amendment in the prosecution of the ’970 Patent, App. No. 12/324122.
`
`10.
`
`Attached hereto as Exhibit 9 is a true and correct copy of the Apr. 5, 2019
`
`Applicant Amendment in the prosecution of the ’1,838 Patent, App. No. 15/809102.
`
` declare under penalty of perjury that the foregoing is true and correct.
`
` I
`
`Executed on September 28, 2021, in San Diego County, California.
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`/s/ Miguel J. Bombach
`Miguel J. Bombach
`
`
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`2
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`
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