`
`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
`
`
`
`DECLARATION OF ALISON T. GELSLEICHTER IN SUPPORT OF
`MAXELL, LTD.’S REPLY TO ITS MOTION TO STRIKE
`PORTIONS OF DEFENDANT APPLE INC.’S REBUTTAL EXPERT REPORTS
`BASED ON UNTMELY CLAIM CONSTRUCTION POSITIONS
`
`I, Alison T. Gelsleichter, 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
`
`to its Motion to Strike Portions of Defendant Apple Inc.’s (“Apple”) Rebuttal Expert Reports
`
`Based on Untimely Claim Construction Positions. 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 21 is a true and correct excerpt from the deposition transcript
`
`of Dr. Harry V. Bims dated June 24, 2020.
`
`3.
`
`Attached as Exhibit 22 is a true and correct copy of Apple’s Petition for Inter
`
`Partes Review of U.S. Patent No. 6,408,193, Case No. IPR2020-00203, dated December 20,
`
`2019.
`
`1
`
`PUBLIC VERSION
`
`
`
`Case 5:19-cv-00036-RWS Document 451-1 Filed 07/27/20 Page 2 of 2 PageID #: 25159
`
`4.
`
`Attached as Exhibit 23 is a true and correct copy of Apple’s Petition for Inter
`
`Partes Review of U.S. Patent No. 7,116,438, Case No. IPR2020-00201, dated December 19,
`
`2019.
`
`5.
`
`Attached as Exhibit 24 is a true and correct excerpt from Apple’s Petition for
`
`Inter Partes Review of U.S. Patent No. 10,212,586, Case No. IPR2020-00202, dated December
`
`19, 2019.
`
`6.
`
`Attached as Exhibit 25 is a true and correct excerpt from Apple’s Petition for
`
`Inter Partes Review of U.S. Patent No. 6,580,999, Case No. IPR2020-00409, dated January 13,
`
`2020.
`
`7.
`
`Attached as Exhibit 26 is a true and correct copy excerpt from the Declaration of
`
`Michael D. Kotzin, Exhibit 1003 to Apple’s Petition for Inter Partes Review of U.S. Patent No.
`
`6,580,999, Case No. IPR2020-00409, dated January 8, 2020.
`
`8.
`
`Attached as Exhibit 27 is a is a true and correct excerpt from Apple’s Petition for
`
`Inter Partes Review of U.S. Patent No. 6,748,317, Case No. IPR2020-00407, dated January 13,
`
`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: ____________________________
`
`Alison T. Gelsleichter
`
`2
`
`
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