`
`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
`
`FILED UNDER SEAL
`
`
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF
`MAXELL, LTD.’S SUR-REPLY IN 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 Sur-
`
`Reply in 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 December 13, 2019, I performed a Google search for “The Digital Camera
`
`Museum.” The first search result was for the website https://www.digitalkameramuseum.de. This
`
`is the website cited by John Gibson in support of Apple’s motion for leave. Gibson Declaration
`
`at ¶ 3 (D.I. 130-1).
`
`3.
`
`On December 13, 2019, I entered “digicammuseum.com” into the address bar of
`
`an
`
`internet browser and
`
`it automatically
`
`redirected
`
`to
`
`the
`
`following website:
`
`https://www.digitalkameramuseum.de/en/. This is the English version of the website cited by
`
`John Gibson in support of Apple’s motion for leave. Gibson Declaration at ¶ 3 (D.I. 130-1).
`
`
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 162-1 Filed 12/13/19 Page 2 of 2 PageID #: 7022
`
`
`
`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 December 13, 2019 in
`
`Washington, D.C.
`
`
`
`Dated: December 13, 2019
`
`
`
`
`
`By:
`
`_______________________
`
`
`
`
`
`Tiffany A. Miller
`
`2
`
`
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