`
`
`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
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`
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF
`MAXELL, LTD.’S SUR-REPLY IN OPPOSITION TO APPLE INC.’S MOTION TO
`STAY PENDING DETERMINATION OF INTER PARTES REVIEW OF THE
`PATENTS-IN-SUIT
`
`
`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 to Stay Pending Determination of Inter
`
`Partes Review of the Patents-in-Suit. 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.
`
`Attached as Exhibit D is a true and correct excerpt from Apple’s Preliminary
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`Reply filed in connection with IPR2020-00199 (Paper 8) on April 21, 2020.
`
`3.
`
`Attached as Exhibit E is a true and correct excerpt from Maxell, Ltd’s Objections
`
`and Responses to Apple Inc.’s First Set of Interrogatories (Nos. 1-16).
`
`
`
`
`
`
`
`
`
`
`
`1
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`
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`Case 5:19-cv-00036-RWS Document 289-1 Filed 04/22/20 Page 2 of 2 PageID #: 10098
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`I declare under penalty of perjury under the laws of the United States of America that the
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`above is true and correct and that this Declaration was executed on April 22, 2020 in
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`Washington, D.C.
`
`
`
`Dated: April 22, 2020
`
`
`
`
`
`By:
`
`_______________________
`
`
`
`
`
`Tiffany A. Miller
`
`2
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`
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