`FILED UNDER SEAL
`
`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 LUIZ MIRANDA IN SUPPORT OF
`MAXELL, LTD.’S MOTION FOR PARTIAL SUMMARY JUDGMENT OF NO
`INVALIDITY OF U.S. PATENT NOS. 6,748,317, 6,580,999, AND 6,430,498 IN VIEW OF
`THE NAVTALK ALLEGED PRIOR ART
`
`
`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. 6,748,317, 6,580,999, and 6,430,498 in
`
`View of the NavTalk alleged Prior Art (the “Motion”). 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 1 is a true and correct excerpt from the Opening Expert Report
`
`of Dr. Joseph A. Paradiso Regarding Invalidity of U.S. Patent Nos. 6,748,317, 6,580,999, and
`
`6,430,498, served on May 7, 2020.
`
`3.
`
`Attached as Exhibit 2 is a true and correct copy of the Expert Report of Robert L.
`
`Stoll, served on June 4, 2020.
`
`4.
`
`Attached as Exhibit 3 is a true and correct copy of the Declaration of David Ayres
`
`dated March 24, 2020.
`
`
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 391-1 Filed 07/06/20 Page 2 of 2 PageID #: 19369
`FILED UNDER SEAL
`
`5.
`
`Attached as Exhibit 4 is a true and correct excerpt from the deposition transcript of
`
`L. Kent Broddle dated April 17, 2020.
`
`
`
`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 July 2, 2020 in Chicago, IL.
`
`Dated: July 2, 2020
`
`
`
`
`
`By: ____________________________
`
`Luiz Miranda
`
`
`
`
`
`2
`
`
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