`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TEXARKANA DIVISION
`
`MAXELL, LTD.,
`
`Plaintiff,
`
`
`
`
`
`
`
`vs.
`
`APPLE INC.,
`
` Civil Action No. 5:19-cv-00036-RWS
`
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`Defendant.
`
`DECLARATION OF LUANN L. SIMMONS IN SUPPORT OF
`APPLE INC.’S REPLY IN SUPPORT OF ITS RENEWED MOTION TO STAY
`PENDING DETERMINATION OF INTER PARTES REVIEW
`
`I, Luann L. Simmons, hereby 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 filed by Plaintiff Maxell, Ltd. (“Maxell”). I have
`
`personal knowledge of the facts stated herein and if called to testify could and would
`
`competently testify thereto.
`
`2.
`
`Attached as Exhibit CC is a true and correct copy of the Scheduling Order for
`
`IPR2020-00199 (U.S. Patent No. 6,329,794) and IPR2020-00204 (U.S. Patent No. 6,928,306),
`
`dated June 19, 2020.
`
`3.
`
`Attached as Exhibit DD is a true and correct copy of the Scheduling Order for
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`IPR2020-00200 (U.S. Patent No. 10,084,991) and IPR2020-00202 (U.S. Patent No. 10,212,586),
`
`dated July 21, 2020.
`
`
`
`
`
`1
`
`
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`Case 5:19-cv-00036-RWS Document 511-1 Filed 08/25/20 Page 2 of 2 PageID #: 27569
`
`
`I declare under the penalty of perjury that the foregoing is true and correct.
`
`Executed in San Francisco, California, on this 25th day of August, 2020.
`
`
`
`/s/ Luann L. Simmons
`Luann L. Simmons
`
`
`
`
`
`2
`
`
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