`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`
`
`Plaintiff
`
`Civil Action NO. 5:19-cv-00036-RWS
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`JURY TRIAL DEMANDED
`
`
`
`
`DECLARATION OF XIN-YI ZHOU IN SUPPORT OF APPLE INC.’S OPPOSITION TO
`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
`
`
`
`
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 441-1 Filed 07/24/20 Page 2 of 3 PageID #: 24285
`
`
`I, Xin-Yi Zhou, declare as follows:
`
`1.
`
`I am an attorney at the law firm of O’Melveny & Myers LLP, counsel for
`
`Defendant Apple Inc. (“Apple”) in this matter instituted by Plaintiff Maxell, Ltd. (“Maxell”). I
`
`am a member in good standing of the State Bar of California and have been admitted to practice
`
`before this Court. The statements below are based on personal knowledge and/or investigation
`
`of the facts stated herein and if called to testify could competently testify to their substance.
`
`2.
`
`Attached as Exhibit A 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, dated
`
`May 7, 2020.
`
`3.
`
`Attached as Exhibit B is a true and correct copy of correspondence to Mayer
`
`Brown LLP from Vincent Zhou, dated February 26, 2020.
`
`4.
`
`Attached as Exhibit C is a true and correct copy of excerpts from the document
`
`with production numbers APL-MAXELL_00716451 to APL-MAXELL_00716582, which was
`
`produced by Apple.
`
`5.
`
`Attached as Exhibit D is a true and correct copy of excerpts from the document
`
`with production numbers APL-MAXELL_01147532 to APL-MAXELL_01147644, which was
`
`produced by Apple.
`
`6.
`
`Attached as Exhibit E is a true and correct copy of a document with production
`
`number APL-MAXELL_00717723, which was produced by Apple.
`
`7.
`
`Attached as Exhibit F is a true and correct copy of excerpts from the document
`
`with production numbers APL-MAXELL_01463585 to APL-MAXELL_01463601, which was
`
`produced by Apple.
`
`8.
`
`Attached as Exhibit G is a true and correct copy of a document with production
`
`numbers APL-MAXELL_01509141 - APL-MAXELL_01509159, which was produced by
`
`2
`
`
`
`Case 5:19-cv-00036-RWS Document 441-1 Filed 07/24/20 Page 3 of 3 PageID #: 24286
`
`
`Apple.
`
`9.
`
`Attached as Exhibit H is a true and correct copy of a document with production
`
`number SCA0003618, which was produced by Sony Corporation of America.
`
`10.
`
`Attached as Exhibit I is a true and correct copy of excerpts from the Expert
`
`Report of Robert L. Stoll, dated June 4, 2020.
`
`11.
`
`Attached as Exhibit J is a true and correct copy of excerpts from the transcript
`
`from the deposition of Maxell’s expert witness, Robert L. Stoll, taken on June 18, 2020.
`
`12.
`
`Attached as Exhibit K is a true and correct copy of excerpts from Apple’s
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`Invalidity Contentions Pursuant to Patent Local Rules 3-3 and 3-4, served on August 14, 2019.
`
` declare under penalty of perjury under the laws of the United States of America that the
`
` I
`
`foregoing is true and correct.
`
`Executed July 22, 2020, in Los Angeles, California.
`
`
`
`/s/ Xin-Yi Zhou
` Xin-Yi Zhou
`
`
`
`
`
`
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`3
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