`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Plaintiff,
`
`Defendant.
`
`Case No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`
`
`DECLARATION OF ALISON T. GELSLEICHTER IN SUPPORT OF
`MAXELL, LTD.’S OPPOSITION TO DEFENDANT APPLE INC.’S MOTION
`TO STRIKE PORTIONS OF MAXELL’S OPENING EXPERT REPORTS THAT
`EXCEED THE SCOPE OF MAXELL’S P.R. 3-1 INFRINGEMENT CONTENTIONS
`AND NEW EXPERT THEORIES OFFERED AFTER EXPERT REPORTS
`
`I, Alison T. Gelsleichter, 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 Defendant Apple Inc.’s (“Apple”) Motion to Strike Portions of Maxell’s Opening
`
`Expert Reports that Exceed the Scope of Maxell’s P.R. 3-1 Infringement Contentions and New
`
`Expert Theories Offered After Expert Reports. 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 Maxell’s Infringement
`
`Contentions Pursuant to Patent Local Rules 3-1 and 3-2 served June 12, 2019 and Maxell’s
`
`Second Supplemental Infringement Contentions Pursuant to Patent Local Rules 3-1 and 3-2
`
`served March 13, 2020 and appendices thereto (collectively, “Infringement Contentions”).
`
`1
`
`PUBLIC VERSION
`
`
`
`Case 5:19-cv-00036-RWS Document 417-1 Filed 07/17/20 Page 2 of 2 PageID #: 21943
`
`3.
`
`Attached as Exhibit 2 is a true and correct excerpt from the Initial Expert Report
`
`of Vijay Madisetti, Ph.D. Concerning Apple’s Infringement of U.S. Patent No. 8,339,493, served
`
`May 7, 2020.
`
`4.
`
`Attached as Exhibit 3 is a true and correct excerpt from the transcript of the
`
`Markman Hearing in the instant case dated January 8, 2020.
`
`5.
`
`Attached as Exhibit 4 is a true and correct excerpt from the Initial Expert Report
`
`of Branimir Vojcic, Ph.D. Concerning Apple’s Infringement of U.S. Patent No. 6,408,193,
`
`served May 7, 2020.
`
`6.
`
`Attached as Exhibit 5 is a true and correct excerpt from the Expert Report of John
`
`Crockett Regarding Source Code Relating to Cellular Functionalities, served May 7, 2020.
`
`7.
`
`Attached as Exhibit 6 is a true and correct excerpt from the deposition transcript
`
`of Tim A. Williams, Ph.D., dated June 25, 2020.
`
`8.
`
`Attached as Exhibit 7 is a true and correct copy of a letter from Jamie Beaber to
`
`Marc Pensabene dated April 13, 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 15, 2020 in Washington,
`
`D.C.
`
`Dated: July 15, 2020
`
`By: ____________________________
`
`Alison T. Gelsleichter
`
`2
`
`
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