`
`
`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
`
`FILED UNDER SEAL
`
`
`
`
`MAXELL, LTD.,
`
`v.
`
`APPLE INC.,
`
`Defendant.
`
`
`
`
`DECLARATION OF TIFFANY A. MILLER IN SUPPORT OF MAXELL, LTD.’S
`OPPOSED MOTION FOR LEAVE TO SUPPLEMENT INFRINGEMENT
`CONTENTIONS TO ADD NEWLY RELEASED PRODUCTS
`
`
`
`
`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
`
`Opposed Motion for Leave to Supplement Infringement Contentions to Add Newly Released
`
`Products. 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 A is a true a correct copy of a press release available on
`
`Apple’s website at the following link:
`
`https://www.apple.com/newsroom/2019/09/iphone-11-pro-iphone-11-pro-max-iphone-
`
`11-and-apple-watch-series-5-arrive-in-stores/
`
`3.
`
`Attached as Exhibit B is a true a correct copy of a press release available on
`
`Apple’s website at the following link:
`
`
`
`1
`
`
`
`Case 5:19-cv-00036-RWS Document 96-1 Filed 10/07/19 Page 2 of 2 PageID #: 4325
`
`
`https://www.apple.com/newsroom/2019/09/apple-introduces-new-version-of-the-most-
`
`popular-ipad-starting-at-329/
`
`4.
`
`Attached as Exhibit C is a true a correct copy of a letter sent from Maxell’s
`
`counsel to Apple’s counsel on September 23, 2019.
`
`
`
`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 October 7, 2019 in
`
`Washington, D.C.
`
`
`
`Dated: October 7, 2019
`
`
`
`
`
`By:
`
`_______________________
`
`Tiffany A. Miller
`
`
`
`2
`
`
`
`
`
`
`
`
`
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