`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
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`MAXELL, LTD.,
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`Plaintiff,
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`vs.
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`APPLE INC.,
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`
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`Defendant.
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` Civil Action No. 5:19-cv-00036-RWS
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`
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`JURY TRIAL DEMANDED
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`DECLARATION OF XIN-YI ZHOU IN SUPPORT OF DEFENDANT APPLE INC.’S
`REPLY IN SUPPORT OF ITS DAUBERT MOTION
`TO EXCLUDE TESTIMONY AND OPINIONS OF MAXELL’S EXPERTS FOR
`IMPROPER APPLICATION OF THE COURT’S CLAIM CONSTRUCTION
`
`I, Xin-Yi Zhou, declare as follows:
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`1.
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`I am an attorney at the law firm of O’Melveny & Myers LLP, counsel for
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`Defendant Apple Inc. (“Apple”) in this matter instituted by Plaintiff Maxell, Ltd. (“Maxell”). I
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`am a member in good standing of the State Bar of California and have been admitted to practice
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`before this Court. The statements below are based on personal knowledge and/or investigation
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`of the facts stated herein and if called to testify could competently testify to their substance.
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`2.
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`Attached as Exhibit 6 is a true and correct copy of excerpts from the transcript
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`from the deposition of Apple’s expert witness, Benjamin B. Bederson, taken on June 19, 2020.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Executed July 23, 2020, in Los Angeles, California.
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`/s/ Xin-Yi Zhou
` Xin-Yi Zhou
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`1
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