`
`
`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 XIN-YI ZHOU IN SUPPORT OF APPLE INC.’S SUR-REPLY IN
`SUPPORT OF ITS OPPOSITION TO MAXELL, LTD.’S MOTION TO STRIKE
`PORTIONS OF APPLE’S REBUTTAL EXPERT REPORTS BASED ON UNTIMELY
`CLAIM CONSTRUCTION POSITIONS
`
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 473-1 Filed 08/03/20 Page 2 of 2 PageID #: 25966
`
`
`I, Xin-Yi Zhou, 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
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`of the facts stated herein and if called to testify could competently testify to their substance.
`
`2.
`
`Attached as Exhibit 21 is a true and correct copy of excerpts from the transcript
`
`from the deposition of Apple’s expert Dr. Joseph A. Paradiso, taken on June 16, 2020.
`
`3.
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`Attached as Exhibit 22 is a true and correct copy of an excerpt from Petition for
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`Inter Partes Review of U.S. Patent No. 6,580,999 (Case No. IPR2020-00409), filed and served
`
`on January 13, 2020.
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`4.
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`Attached as Exhibit 23 is a true and correct copy of an excerpt from Petition for
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`Inter Partes Review of U.S. Patent No. 6,748,317 (Case No. IPR2020-00407), filed and served
`
`on January 13, 2020.
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` declare under penalty of perjury under the laws of the United States of America that the
`
` I
`
`foregoing is true and correct.
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`Executed July 30, 2020, in Los Angeles, California.
`
`
`
`/s/ Xin-Yi Zhou
` Xin-Yi Zhou
`
`
`
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`2
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