`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`Plaintiff,
`
`
`
`
`
`
`
`vs.
`
`APPLE INC.,
`
`
`
`
`
`Defendant.
`
` Civil Action No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`DECLARATION OF MELODY DRUMMOND HANSEN IN SUPPORT OF
`DEFENDANT APPLE INC.’S OPPOSITION DEFENDANT MAXELL, LTD.’S MOTION
`TO STRIKE PORTIONS OF DEFENDANT APPLE INC.’S OPENING EXPERT
`REPORTS
`
`I, Melody Drummond Hansen, hereby declare as follows:
`
`1.
`
`I am an attorney at the law firm of O’Melveny & Myers LLP, counsel for Apple,
`
`Inc. (“Apple”) in this matter filed by Maxell, Ltd. (“Maxell”). I have personal knowledge of the
`
`facts stated herein and if called to testify could and would competently testify thereto.
`
`2.
`
`Attached as Exhibit 19 are true and correct copies of excerpts from U.S. Patent
`
`No. 10,212,586 Patent File history (MAXELL_APPLE0002073-78, MAXELL_APPLE0002039-
`
`41, MAXELL_APPLE0002047-50).
`
`3.
`
`Attached as Exhibit 20 is a true and correct copy of Exhibit D2 from Apple’s
`
`Invalidity Contentions served August 14, 2019.
`
`4.
`
`Attached as Exhibit 21 are true and correct copies of excerpts from Exhibit E2 from
`
`Apple’s Invalidity Contentions served August 14, 2019.
`
`5.
`
`Attached as Exhibit 22 are true and correct copies of excerpts from Exhibit H2
`
`from Apple’s Invalidity Contentions served August 14, 2019.
`
`
`
`
`
`Case 5:19-cv-00036-RWS Document 348-1 Filed 06/18/20 Page 2 of 3 PageID #: 12220
`
`
`6.
`
`Attached as Exhibit 23 are true and correct copies of excerpts from Defendant
`
`Apple Inc.’s First Supplemental Invalidity Contentions Pursuant to Patent Local Rules 3-3 and 3-
`
`4 served March 4, 2020.
`
`7.
`
`Attached as Exhibit 24 are true and correct copies of excerpts from Exhibit E6 from
`
`Apple’s Invalidity Contentions served August 14, 2019.
`
`8.
`
`Attached as Exhibit 25 is a true and correct copy Exhibit G3 from Apple’s
`
`Invalidity Contentions served August 14, 2019.
`
`9.
`
`Attached as Exhibit 26 is a true and correct copy of Exhibit D1 from Apple’s
`
`Invalidity Contentions served August 14, 2019.
`
`10.
`
`Attached as Exhibit 27 are true and correct copies of excerpts from Defendant
`
`Apple Inc.’s First Supplemental Invalidity Contentions Pursuant to Patent Local Rules 3-3 and 3-
`
`4 served March 4, 2020.
`
`11.
`
`Attached as Exhibit 28 is a true and correct copy of Exhibit A10 from Apple’s
`
`Invalidity Contentions served August 14, 2019.
`
`12.
`
`Attached as Exhibit 29 is a true and correct copy of Exhibit A19 from Apple’s
`
`Invalidity Contentions served August 14, 2019.
`
`13.
`
`Attached as Exhibit 30 is a true and correct copy of Exhibit A21 from Apple’s
`
`Invalidity Contentions served August 14, 2019.
`
`14.
`
`Attached as Exhibit 31 is a true and correct copy of Exhibit A11 from Apple’s
`
`Invalidity Contentions served August 14, 2019.
`
`15.
`
`Attached as Exhibit 32 are true and correct copies of excerpts from the Opening
`
`Expert Report of Dr. Joseph A. Paradiso Regarding Invalidity of U.S. Patent Nos. 6,748,317,
`
`6,580,999, 6,430,498 served May 7, 2020.
`
`
`
`
`
`Case 5:19-cv-00036-RWS Document 348-1 Filed 06/18/20 Page 3 of 3 PageID #: 12221
`
`
` declare under the penalty of perjury that the foregoing is true and correct. Executed in
`
` I
`
`San Francisco, California, on this 15th day of June, 2020.
`
`
`
`/s/ Melody Drummond Hansen
`
` Melody Drummond Hansen
`
`
`
`
`
`
`
`
`
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