`
`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 OPPOSITION TO APPLE’S MOTION TO EXCLUDE THE
`TESTIMONY OF ROBERT L. STOLL
`
`
`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 Opposition to
`
`Apple’s Motion to Exclude the Testimony of Robert L. Stoll. 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 copy of the Expert Report of Robert L.
`
`Stoll, served on June 4, 2020.
`
`3.
`
`Attached as Exhibit 2 is a true and correct copy of excerpts from the deposition
`
`transcript of Robert L. Stoll dated June 18, 2020.
`
`4.
`
`Attached as Exhibit 3 is a true and correct copy 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,
`
`and 6,430,498, served on May 7, 2020.
`
`
`
`1
`
`PUBLIC VERSION
`
`PUBLIC VERSION
`
`
`
`Case 5:19-cv-00036-RWS Document 408-1 Filed 07/16/20 Page 2 of 2 PageID #: 21496
`
`5.
`
`Attached as Exhibit 4 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.
`
`6.
`
`Attached as Exhibit 5 is a true and correct copy of the Expert Report of Jacob Robert
`
`Munford Concerning Publication and Public Accessibility and exhibits thereto, served on May 7,
`
`2020.
`
`7.
`
`Attached as Exhibit 6 is a true and correct copy of excerpts from the USPTO
`
`Manual of Patent Examining Procedure, Ninth Edition, Revision 10.2019, Last Revised June 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 14, 2020 in Chicago, IL.
`
`Dated: July 14, 2020
`
`
`
`By: ____________________________
`
`Luiz Miranda
`
`
`
`
`
`2
`
`PUBLIC VERSION
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
