Case 4:23-cv-01147-ALM Document 90-1 Filed 02/19/25 Page 1 of 4 PageID #:
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`R2 SOLUTIONS LLC,
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`Plaintiff,
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`v.
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`DATABRICKS, INC.,
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`Defendant.
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`Civil Action No. 4:23-cv-01147-ALM
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`JURY TRIAL DEMANDED
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`DECLARATION OF MICHAEL J. SACKSTEDER IN SUPPORT OF
`DEFENDANT DATABRICKS, INC.’S OPPOSITION TO PLAINTIFF’S
`MOTION TO COMPEL DISCOVERY AND AMEND SCHEDULING ORDER
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`Case 4:23-cv-01147-ALM Document 90-1 Filed 02/19/25 Page 2 of 4 PageID #:
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`I, Michael J. Sacksteder, declare as follows:
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`1.
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`I am an attorney admitted to practice before this Court and am a partner with the
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`law firm of Fenwick & West LLP, counsel for Defendant Databricks, Inc. (“Databricks”). I have
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`personal knowledge of the matters set forth in this declaration and, if called upon to do so, could
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`and would testify competently as to the matters set forth herein.
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`2.
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`Attached hereto as Exhibit A is a true and correct copy of U.S. Patent No.
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`8,190,610.
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`3.
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`Attached hereto as Exhibit B is a true and correct copy of Plaintiff’s Initial
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`Infringement Contentions, served on June 21, 2024.
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`4.
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`Attached hereto as Exhibit C is a true and correct copy of a Databricks webpage
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`titled “What is Photon?” produced in this case with Beginning Bates No. Databricks_R2_00008580.
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`5.
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`Attached hereto as Exhibit D is a true and correct excerpt from the December 5,
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`2024 deposition transcript of Denny Lee.
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`6.
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`Attached hereto as Exhibit E is a true and correct excerpt from the December 13,
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`2024 deposition transcript of Cody Davis.
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`7.
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`Attached hereto as Exhibit F is a true and correct excerpt from the January 16,
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`2025 deposition transcript of Josh Rosen.
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`8.
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`Attached hereto as Exhibit G is a true and correct excerpt from the January 24,
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`2025 deposition transcript of Reynold Xin.
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`9.
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`Attached hereto as Exhibit H is a true and correct copy of the Declaration of
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`Yuanjian Li in Support of Defendant Databricks, Inc.’s Opposition to Plaintiff’s Motion to Compel
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`Discovery.
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`1
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`Case 4:23-cv-01147-ALM Document 90-1 Filed 02/19/25 Page 3 of 4 PageID #:
`6307
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`10.
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`Attached hereto as Exhibit I is a true and correct excerpt from the January 24, 2025
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`deposition transcript of Reynold Xin.
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`11.
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`Attached hereto as Exhibit J is a true and correct copy of a Databricks webpage
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`titled “Announcing Photon Public Preview: The Next Generation Query Engine on the Databricks
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`Lakehouse Platform” produced in this case with Beginning Bates No. Databricks_R200087824.
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`12.
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`Attached here to as Exhibit K is a true and correct excerpt of email correspondence
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`between counsel of record for Plaintiff R2 Solutions, LLC and counsel of record for Defendant
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`Databricks, Inc. as it relates to Photon source code.
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` declare under penalty of perjury that the foregoing is true and correct. Executed this
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`12th day of February, 2025.
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`/s/ Michael J. Sacksteder
`Michael J. Sacksteder
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`2
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`Case 4:23-cv-01147-ALM Document 90-1 Filed 02/19/25 Page 4 of 4 PageID #:
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`CERTIFICATE OF AUTHORIZATION TO SEAL
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`Pursuant to Lcal Rule CV-5(a)(7)(B), I am authorized to file the foregoing document under
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`seal pursuant to the Protective Order (Dkt. 61) because this document references Designated
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`Material.
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`Dated: February 12, 2025
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`/s/ Michael J. Sacksteder
`Michael J. Sacksteder
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true and correct copy of the above and foregoing
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`document has been served on all counsel of record who are demed to have consented to electronic
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`service via the Court’s CM/ECF system. Additionally, I hereby certify that all counsel of record
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`who have consented to electronic service are being served with a copy of these documents via
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`electronic mail per Local Rule CV-5.
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`Dated: February 12, 2025
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`/s/ Michael J. Sacksteder
`Michael J. Sacksteder
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`3
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