`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`v.
`
`ZTE USA INC.,
`
`Plaintiff,
`
`Defendants.
`
`Case No. 5:16-cv-00179-RWS
`
`JURY TRIAL DEMANDED
`
`DECLARATION OF SAQIB J. SIDDIQUI IN SUPPORT OF
`PLAINTIFF MAXELL, LTD.’S POST-TRIAL MOTIONS AND
`RENEWED MOTION FOR JUDGMENT AS A MATTER OF LAW
`
`I, Saqib J. Siddiqui, declare as follows.
`
`1.
`
`I am an attorney with the law firm of Mayer Brown LLP. I am admitted to
`
`practice in the Eastern District of Texas. I represent Plaintiff Maxell, Ltd. in the above-captioned
`
`action.
`
`2.
`
`I am submitting this declaration on behalf of Maxell in support of its Post-Trial
`
`Motions and Renewed Motion for Judgment as a Matter of Law.
`
`3.
`
`4.
`
`I attended the June 18-29, 2018 trial and assisted with witness preparation.
`
`Maxell’s expert witness for the ’794 patent, Dr. Joshua Phinney, was in
`
`Texarkana, TX, preparing with Maxell attorneys for his trial testimony (including validity
`
`testimony) for a time period that included June 11 through June 17. This work included
`
`preparation for testimony on prior art that ZTE then dropped from the case on the day the parties
`
`exchanged opening slides.
`
`- 1 -
`
`
`
`Case 5:16-cv-00179-RWS Document 287-2 Filed 08/07/18 Page 2 of 3 PageID #: 16780
`
`5.
`
`Maxell’s expert witness on the ’493 and ’729 patents, Dr. Vijay Madisetti, was in
`
`Texarkana, TX, preparing with Maxell attorneys for his trial testimony (including validity
`
`testimony) for a time period that included June 11 through June 17. This work included
`
`preparation for testimony on prior art on which Maxell moved for summary judgment of no
`
`invalidity, and which ZTE opposed and fully briefed and argued in front of the Court before
`
`dropping on June 17. It was Maxell’s understanding until June 17 that ZTE would be presenting
`
`these invalidity grounds at trial.
`
`6.
`
`Maxell’s expert witness for the ’491 and ’695 Patents, Dr. Robert Maher, was in
`
`Texarkana, TX, preparing with Maxell attorneys for his trial testimony (including validity
`
`testimony) for a time period that included June 11 through his infringement testimony on June
`
`22. work prior to June 11 included preparation for testimony on prior art that was not disclosed
`
`in ZTE’s invalidity contentions.
`
`7.
`
`After his direct testimony, Dr. Maher left and returned to Texarkana, TX, on June
`
`24, 2018, solely to prepare for his rebuttal validity testimony. Dr. Maher prepared with Maxell
`
`attorneys for his validity testimony through June 27, 2018.
`
`8.
`
`Maxell’s expert witness for the ’193 patent, Dr. Michael Caloyannides, was in
`
`Texarkana, TX, preparing with Maxell attorneys for his trial testimony (including validity
`
`testimony) for a time period that included June 12 through June 17. This preparation covered the
`
`prior art grounds that ZTE never presented at trial. It was Maxell’s understanding until Dr.
`
`Ding’s testimony that ZTE would be presenting these invalidity grounds at trial.
`
`9.
`
`I hereby declare under penalty of perjury that the foregoing statements are true
`
`and accurate to the best of my knowledge, information, and belief.
`
`- 2 -
`
`
`
`Case 5:16-cv-00179-RWS Document 287-2 Filed 08/07/18 Page 3 of 3 PageID #: 16781
`
`Executed on August 3, 2018.
`
`Saqib J. Siddiqui
`
`_____
`
`- 3 -
`
`
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