`
`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
`
`FILED UNDER SEAL
`
`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF
`MAXELL, LTD.’S REPLY IN SUPPORT OF OPPOSED MOTION TO STRIKE MR.
`GUNDERSON’S USE OF OFFERS MADE IN LICENSING NEGOTIATIONS AND
`EXCLUDE TESTIMONY REGARDING THE SAME
`
`I, Tiffany A. Miller, 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 Reply
`
`in Support of Opposed Motion to Strike Mr. Gunderson’s Use of Offers Made in Licensing
`
`Negotiations and Exclude Testimony Regarding the Same. 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 I are true and correct excerpts from the Deposition Transcript
`
`of Kenji Nakamura, dated February 21, 2020.
`
`3.
`
`Attached as Exhibit J are true and correct excerpts from the Deposition Transcript
`
`of Alan Loudermilk, dated April 28, 2020.
`
`4.
`
`Attached as Exhibit K are true and correct excerpts from the Deposition
`
`Transcript of Heather Mewes, dated April 15, 2020.
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 450-1 Filed 07/27/20 Page 2 of 2 PageID #: 25143
`
`5.
`
`Attached as Exhibit L are true and correct excerpts of Maxell, Ltd.’s Third
`
`Supplemental Objections and Responses to Apple Inc.’s First Set of Interrogatories, dated March
`
`31, 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 23, 2020 in Washington,
`
`D.C.
`
`Dated: July 23, 2020
`
`By:
`
`_______________________
`
`Tiffany A. Miller
`
`2
`
`
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