`
`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 LUIZ MIRANDA IN SUPPORT OF MAXELL, LTD.’S
` REPLY IN SUPPORT OF ITS 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 THE ABOWD AND CYBERGUIDE ALLEGED PRIOR ART
`
`
`I, Luiz Miranda, 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 its 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 the Abowd and Cyberguide alleged Prior Art. 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 5 is a true and correct copy of a publication titled “Cyberguide:
`
`A Mobile Context-Aware Tour Guide” with authors listed as Gregory Abowd, et. al, bearing bates
`
`no. APL-MAXELL_00713087-APL-MAXELL_00713107 (“Abowd”).
`
`
`
`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 30, 2020 in Chicago, IL.
`
`
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 457-1 Filed 07/30/20 Page 2 of 2 PageID #: 25550
`
`Dated: July 30, 2020
`
`
`
`By: ____________________________
`
`Luiz Miranda
`
`
`
`
`
`2
`
`
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