`
`
`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 LUIZ MIRANDA IN SUPPORT OF
`MAXELL, LTD.’S MOTION FOR PARTIAL SUMMARY JUDGMENT OF NO
`INVALIDITY OF U.S. PATENT NO. 8,339,493 IN VIEW OF THE
`SONY MVC-FD83 AND MVC-FD88 CAMERAS
`
`
`I, Luiz Miranda, 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 Motion for Partial
`
`Summary Judgment of No Invalidity of U.S. Patent Nos. 8,339,493 in View of the Sony MVC-
`
`FD83 and MVC-FD88 Cameras (the “Motion”). I have personal knowledge of the statements
`
`herein.
`
`2.
`
`Attached as Exhibit 1 is a true and correct copy of excerpts from the Opening Expert
`
`Report of Dr. Alan C. Bovik Regarding Invalidity of U.S. Patent No. 8,339,493, served on May 7,
`
`2020.
`
`3.
`
`Attached as Exhibit 2 is a true and correct copy of the Subpoena to Sony to Produce
`
`Documents, served on March 6, 2020.
`
`4.
`
`Attached as Exhibit 3 is a true and correct copy of the Subpoena to Sony to Testify
`
`at a Deposition, served on March 6, 2020.
`
`
`
`1
`
`PUBLIC VERSION
`
`
`
`Case 5:19-cv-00036-RWS Document 380-2 Filed 07/02/20 Page 2 of 2 PageID #: 18086
`
`
`5.
`
`Attached as Exhibit 4 is a true and correct copy of the Sony Service Manual for
`
`MVC-FD83/FD88 Cameras (produced in this litigation as SCA0004377).
`
`6.
`
`Attached as Exhibit 5 is a true and correct copy of Sony Sales Data (produced in
`
`this litigation as SCA0004493).
`
`7.
`
`Attached as Exhibit 6 is a true and correct copy of the Declaration of Susan West,
`
`dated March 27, 2020.
`
`8.
`
`Attached as Exhibit 7 is a true and correct copy of an image of a first sample of an
`
`MVC-FD88 camera (APL-MAXELL_P06) (the image produced as MAXELL_APPLE0274104).
`
`9.
`
`Attached as Exhibit 8 is a true and correct copy of an image of a second sample of
`
`an MVC-FD88
`
`camera
`
`(APL-MAXELL_P07)
`
`(the
`
`image
`
`produced
`
`as APL-
`
`MAXELL_01099037).
`
`10.
`
`Attached as Exhibit 9 is a true and correct copy of an of the first sample MVC-
`
`FD88 camera (produced as MAXELL_APPLE0274105).
`
`11.
`
`Attached as Exhibit 10 is a true and correct copy of an image of the second sample
`
`MVC-FD88 camera (produced as APL-MAXELL_01099039).
`
`12.
`
`Attached as Exhibit 11 is a true and correct copy of a Sony Digital Image Training
`
`Guide (produced as SCA0003619).
`
`
`
`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 June 30, 2020, in Chicago, IL.
`
`Dated: June 30, 2020
`
`
`
`By: ____________________________
`
`
`
`Luiz Miranda
`
`2
`
`
`
`
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