`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`Plaintiff,
`
`
`
`
`
`
`
`vs.
`
`APPLE INC.,
`
`
`
`Defendant.
`
`
`
`
`
` Civil Action No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`
`
`DECLARATION OF MELODY DRUMMOND HANSEN IN SUPPORT OF
`APPLE INC.’S OPPOSITION TO MAXELL, LTD.’S MOTION FOR SUMMARY
`JUDGMENT OF NO INVALIDITY UNDER 35 U.S.C. §§ 102 AND 103 OF
`CLAIMS 7, 16, AND 17 FOR U.S. PATENT NO. 10,212,586
`
`I, Melody Drummond Hansen, hereby declare as follows:
`
`1.
`
`I am an attorney at the law firm of O’Melveny & Myers LLP, counsel for Apple,
`
`Inc. (“Apple”) in this matter filed by Maxell, Ltd. (“Maxell”). I have personal knowledge or am
`
`informed of the facts stated herein and if called to testify could and would competently testify
`
`thereto.
`
`2.
`
`Attached as Exhibit 1 is a true and correct annotated copy of U.S. Patent No.
`
`10,212,586 (“the ’586 Patent”).
`
`3.
`
`Attached as Exhibit 2 is a true and correct annotated copy of U.S. Patent No.
`
`6,871,063 (“Schiffer”).
`
`4.
`
`Attached as Exhibit 3 is a true and correct annotated copy of U.S. Published Patent
`
`Application No. US 2006/0041746 (“Kirkup”).
`
`5.
`
`Attached as Exhibit 4 is a true and correct annotated copy of excerpts from the
`
`Opening Expert Report of Dr. Daniel A. Menascé Regarding U.S. Patent Nos. 7,116,438 and
`
`10,212,586, dated May 7, 2020.
`
`
`
`
`
`Case 5:19-cv-00036-RWS Document 442-1 Filed 07/24/20 Page 2 of 2 PageID #: 24398
`
`
`6.
`
`Attached as Exhibit 5 is a true and correct annotated copy of Appendix D to the
`
`Opening Expert Report of Dr. Daniel A. Menascé Regarding U.S. Patent Nos. 7,116,438 and
`
`10,212,586, dated May 7, 2020.
`
`7.
`
`Attached as Exhibit 6 is a true and correct annotated copy of excerpts from the
`
`Rebuttal Expert Report of Tim Williams, Ph.D. Concerning Validity of U.S. Patent Nos. 7,116,438
`
`and 10,212,586, dated June 4, 2020.
`
`I declare under the penalty of perjury that the foregoing is true and correct. Executed in
`
`San Francisco, California, on this 22nd day of July, 2020.
`
`
`
`/s/ Melody Drummond Hansen
`
` Melody Drummond Hansen
`
`
`
`
`
`
`
`
`
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
