`
`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
`SUR-REPLY TO ITS OPPOSITION TO DEFENDANT APPLE INC.’S MOTION
`TO STRIKE PORTIONS OF MAXELL’S OPENING EXPERT REPORTS THAT
`EXCEED THE SCOPE OF MAXELL’S P.R. 3-1 INFRINGEMENT CONTENTIONS
`AND NEW EXPERT THEORIES OFFERED AFTER EXPERT REPORTS
`
`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 Sur-
`
`Reply to its Opposition to Defendant Apple Inc.’s (“Apple”) Motion to Strike Portions of
`
`Maxell’s Opening Expert Reports that Exceed the Scope of Maxell’s P.R. 3-1 Infringement
`
`Contentions and New Expert Theories Offered After Expert Reports. 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 8 is a true and correct excerpt from Maxell’s Infringement
`
`Contentions Pursuant to Patent Local Rules 3-1 and 3-2 served June 12, 2019 and appendices
`
`thereto (collectively, “Infringement Contentions”).
`
`1
`
`PUBLIC VERSION
`
`
`
`Case 5:19-cv-00036-RWS Document 480-1 Filed 08/03/20 Page 2 of 2 PageID #: 26074
`
`3.
`
`Attached as Exhibit 9 is a true and correct excerpt from Apple’s presentation to
`
`the Court for the hearing on Maxell’s Motion to Strike Portions of Apple’s Invalidity Expert
`
`Reports, dated July 15, 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 30, 2020 in Washington,
`
`D.C.
`
`Dated: July 30, 2020
`
`By: ____________________________
`
`Alison T. Gelsleichter
`
`2
`
`
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