`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`
`Plaintiff,
`
`Case No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF
`MAXELL, LTD.’S OPPOSITION TO APPLE’S MOTION FOR LEAVE TO
`SUPPLEMENT INVALIDITY CONTENTIONS
`
`
`I, Tiffany A. Miller, hereby declare and state as follows:
`
`1.
`
`I am an attorney at Mayer Brown LLP, counsel for Plaintiff Maxell, Ltd.
`
`(“Maxell”) in the above-captioned lawsuit. I submit this declaration in support of Maxell’s
`
`Opposition to Apple Inc.’s (“Apple”) Motion for Leave to Supplement Invalidity Contentions. I
`
`have personal knowledge of the statements herein, and, if called to do so, I could and would
`
`testify competently as to the same.
`
`2.
`
`On July 10, 2019, Maxell produced a document bearing bates number
`
`MAXELL_APPLE0190983 – MAXELL_APPLE0190999. The document contains screenshots
`
`from The Digital Camera Museum website that were taken in March 2018.
`
`3.
`
`The below is a true and accurate excerpt of the document bearing bates number
`
`MAXELL_APPLE0190983 – MAXELL_APPLE0190999 that was produced on July 10, 2019:
`
`
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 148-1 Filed 11/29/19 Page 2 of 4 PageID #: 6140
`
`4.
`
`On the page marked MAXELL_APPLE0190995, the produced website identifies
`
`Casio QV-8000SX (1999) in the lower left-hand corner.
`
`5.
`
`The below is a screenshot taken from the website http://digitalkameramuseum.de
`
`on November 21, 2019:
`
`
`
`
`
`2
`
`
`
`Case 5:19-cv-00036-RWS Document 148-1 Filed 11/29/19 Page 3 of 4 PageID #: 6141
`
`6.
`
`On November 21, 2019, I searched the manuals at support.casio.com and located
`
`the User’s Guide for the QV-8000SX. The below is a screenshot of the support.casio.com
`
`website that was taken on November 21, 2019:
`
`
`
`
`
`3
`
`
`
`
`
`Case 5:19-cv-00036-RWS Document 148-1 Filed 11/29/19 Page 4 of 4 PageID #: 6142
`
`7.
`
`The below is a screenshot of the User’s Guide available at the support.casio.com
`
`website that was taken on November 21, 2019:
`
`
`
`8.
`
`Apple Inc. served its Invalidity Contentions Pursuant to Patent Local Rules 3-3
`
`and 3-4 on August 14, 2019. In those contentions, for the ’493 Patent, Apple identified 28 Prior
`
`Art Patents and Publications and 5 Prior Art Systems.
`
`
`
`I declare under penalty of perjury under the laws of the United States of America that the
`
`above is true and correct and that this Declaration was executed on November 29, 2019 in
`
`Washington, D.C.
`
`
`
`Dated: November 29, 2019
`
`
`
`
`
`By:
`
`_______________________
`
`
`
`
`
`Tiffany A. Miller
`
`4
`
`
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