`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`
`Plaintiff,
`
`Case No. 5:19-cv-00036-RWS
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF
`MAXELL, LTD.’S SUR-REPLY IN OPPOSITION TO APPLE INC.’S DAUBERT
`MOTION TO EXCLUDE THE OPINIONS AND TESTIMONY OF PLAINTIFF’S
`DAMAGES EXPERT MS. CARLA MULHERN
`
`
`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 Sur-
`
`Reply in Opposition to Apple Inc.’s Daubert Motion to Exclude the Opinions and Testimony of
`
`Plaintiff’s Damages Expert Ms. Carla Mulhern. 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.
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`Attached as Exhibit 33 are true and correct excerpts from the Initial Expert
`
`Reports of Maxell’s Technical Experts Concerning Apple’s Infringement relating to the experts’
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`analyses of Apple’s alleged non-infringing alternatives.
`
`
`
`I declare under penalty of perjury under the laws of the United States of America that the
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`above is true and correct and that this Declaration was executed on July 30, 2020 in Washington,
`
`D.C.
`
`
`
`1
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`PUBLIC VERSION
`
`
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`Case 5:19-cv-00036-RWS Document 478-1 Filed 08/03/20 Page 2 of 2 PageID #: 26060
`
`
`Dated: July 30, 2020
`
`
`
`
`
`By:
`
`_______________________
`
`
`
`
`
`
`
`Tiffany A. Miller
`
`2
`
`
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