`
`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 DAUBERT
`MOTION TO EXCLUDE TESTIMONY AND OPINIONS OF MAXELL’S EXPERTS
`FOR IMPROPER APPLICATION OF THE COURT’S CLAIM CONSTRUCTION
`
`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”) Daubert Motion to Exclude
`
`Testimony and Opinions of Maxell’s Experts for Improper Application of the Court’s Claim
`
`Construction. 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 9 is a true and correct excerpt from the Initial Expert Report
`
`of Maja Bystrom, Ph.D. Concerning Apple’s Infringement of U.S. Patent No. 10,084,991, served
`
`May 7, 2020.
`
`3.
`
`Attached as Exhibit 10 is a true and correct excerpt from the deposition transcript
`
`of Maja Bystrom, Ph.D., dated June 17, 2020.
`
`1
`
`PUBLIC VERSION
`
`
`
`Case 5:19-cv-00036-RWS Document 483-1 Filed 08/04/20 Page 2 of 2 PageID #: 26437
`
`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 31, 2020 in Washington,
`
`D.C.
`
`Dated: July 31, 2020
`
`By: ____________________________
`
`Alison T. Gelsleichter
`
`2
`
`
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