`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
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`ANCORA TECHNOLOGIES, INC.,
`
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`Plaintiff,
`
`v.
`
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`LG ELECTRONICS, INC. and LG
`ELECTRONICS U.S.A., INC.,
`
`
`Defendants.
`
`
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`CIVIL ACTION NO. 1:20-CV-00034-ADA
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`
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`JURY TRIAL DEMANDED
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`ANCORA TECHNOLOGIES, INC.,
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`
`Plaintiff,
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`v.
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`SAMSUNG ELECTRONICS CO., LTD.,
`and SAMSUNG ELECTRONICS
`AMERICA, INC.,
`
`
`Defendants.
`
`
`
`CIVIL ACTION NO. 1:20-CV-00034-ADA
`
`
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`JURY TRIAL DEMANDED
`
`
`
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`DECLARATION OF THOMAS E. GARTEN IN SUPPORT OF DEFENDANTS
`SAMSUNG ELECTRONICS CO., LTD. AND SAMSUNG ELECTRONICS
`AMERICA, INC.’S RESPONSE TO PLAINTIFF’S MOTION FOR PARTIAL
`SUMMARY JUDGMENT
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`
`
`I, Thomas E. Garten, declare and state as follows:
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`1.
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`I am over the age of eighteen years, of sound mind, and competent to make this
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`declaration. I am an attorney at the law firm of Covington & Burling LLP and represent
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`Defendants Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (“Samsung”)
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`in the above-captioned case. I have personal knowledge of the facts set forth in this declaration
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`and, if called as a witness, I would testify competently to these facts.
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`
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`Case 1:20-cv-00034-ADA Document 150 Filed 02/17/21 Page 2 of 2
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`2.
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`Attached as Exhibit 21 to this Declaration is a true and correct copy of
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`correspondence to Limelight Networks, Inc. dated July 23, 2020.
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`3.
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`Attached as Exhibit 22 to this Declaration is a true and correct copy of an excerpt
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`from email exchanges with counsel for Ancora.
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`4.
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`Attached as Exhibit 23 to this Declaration is a true and correct copy of excerpts
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`from the January 14, 2021 and January 15, 2021 deposition of David Martin, Ph.D.
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`I declare under penalty of perjury that the foregoing is true and correct to the best of my
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`knowledge. This declaration was executed on February 17, 2021, in Oakland, CA.
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`
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`Dated: February 17, 2021
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`Respectfully submitted,
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`/s/ Thomas E. Garten
`
`Thomas E. Garten
`3000 El Camino Real
`5 Palo Alto Square, 10th Floor
`Palo Alto, CA 94306-2112
`Phone: (650) 632-4708
`Email: tgarten@cov.com
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`2
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