`
`
`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 MARK LIANG IN SUPPORT OF APPLE INC.’S BRIEF IN
`OPPOSITION TO 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 ABOWD AND CYBERGUIDE
`
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 447-1 Filed 07/27/20 Page 2 of 3 PageID #: 24863
`
`
`I, Mark Liang, 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 1 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, 6,430,498, dated May 7, 2020.
`
`3.
`
`Attached as Exhibit 2 is a true and correct copy of the Expert Report Of Jacob
`
`Robert Munford Concerning Publication And Public Accessibility, dated May 7, 2020.
`
`4.
`
`Attached as Exhibit 3 is a true and correct copy of a screenshot of a webpage
`
`titled “Library Research at Cornell: Library Jargon,” from the Cornell University Library
`
`website, printed on July 10, 2020.
`
`5.
`
`Attached as Exhibit 4 is a true and correct copy of a screenshot of a webpage
`
`titled “What does "non-circulating" mean?” from the Yale University Library website, printed on
`
`July 10, 2020.
`
`6.
`
`Attached as Exhibit 5 is a true and correct copy of the transcript from Jacob
`
`Robert Munford’s deposition, taken on June 19, 2020.
`
`7.
`
`Attached as Exhibit 6 is a true and correct copy of excerpts from an article titled
`
`“Cyberguide: A Mobile Context-Aware Tour Guide,” by Gregory D. Abowd et al., dated
`
`September 23, 1996.
`
`8.
`
`Attached as Exhibit 7 is a true and correct copy of excerpts from Defendant Apple
`
`Inc.’s Second Amended Initial And Additional Disclosures, Filed March 5, 2020.
`
`2
`
`
`
`Case 5:19-cv-00036-RWS Document 447-1 Filed 07/27/20 Page 3 of 3 PageID #: 24864
`
`
`9.
`
`Attached as Exhibit 8 is a true and correct copy of Apple Inc.’s Trial Witness List,
`
`served on June 25, 2020.
`
`10.
`
`Attached as Exhibit 9 is a true and correct copy of the transcript from Dr. Joseph
`
`A. Paradiso’s deposition, taken on June 16, 2020.
`
`11.
`
`Attached as Exhibit 10 is a true and correct copy of excerpts from the Expert
`
`Report Of Robert Stoll, dated June 4, 2020.
`
`12.
`
`Attached as Exhibit 11 is a true and correct copy of excerpts from the transcript
`
`from Robert Stoll’s deposition, taken on June 18, 2020.
`
`13.
`
`Attached as Exhibit 12 is a true and correct copy of a screenshot of the Class
`
`Profile for the 2019 fall semester, from the University of Pittsburgh Admissions website, printed
`
`on July 3, 2020.
`
`14.
`
`Attached as Exhibit 13 is a true and correct copy of a screenshot of a webpage
`
`titled “Why Work at Pitt?” from the University of Pittsburgh Office of Human Resources,
`
`printed on July 3, 2020.
`
`15.
`
`Attached as Exhibit 14 is a true and correct copy of a screenshot of the front page
`
`of the University of Pittsburgh Alumni website, printed on July 3, 2020.
`
`I declare under penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct.
`
`Executed July 23, 2020, in San Francisco, California.
`
`
`
`/s/ Mark Liang
` Mark Liang
`
`
`
`
`
`
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`3
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