Case 6:19-cv-00537-ADA Document 48-1 Filed 06/25/20 Page 1 of 4
`
`UNITED STATES DISTRICT C OURT
`FOR THE WESTERN DISTRICT OF TEX AS
`WACO DIVISION
`
`SOLAS OLED LTD.,
`
`
`
`v.
`DELL INC.,
`
`
`
`
`
`SOLAS OLED LTD.,
`
`
`
`v.
`GOOGLE LLC,
`
`
`
`
`
`SOLAS OLED LTD.,
`
`
`
`v.
`APPLE INC.,
`
`
`
`
`
`SOLAS OLED LTD.,
`
`
`
`v.
`HP INC.,
`
`
`
`Plaintiff,
`
`Defendant.
`
`Plaintiff,
`
`Defendant.
`
`Plaintiff,
`
`Defendant.
`
`Plaintiff,
`
`Defendant
`
`
`
`Case No. 6:19-cv-00514-ADA
`
`
`
`
`
`Case No. 6:19-cv-00515-ADA
`
`
`
`
`
`Case No. 6:19-cv-00537-ADA
`
`
`
`
`
`Case No. 6:19-cv-00631-ADA
`
`
`
`
`
`
`
`DECLARATION OF PHILIP X. WANG IN SUPPORT OF
`SOLAS’S OPENING CLAIM CONSTRUCTION BRIEF
`
`1
`
`
`
`UNITED STATES DISTRICT C OURT
`FOR THE WESTERN DISTRICT OF TEX AS
`WACO DIVISION
`
`SOLAS OLED LTD.,
`
`
`
`v.
`DELL INC.,
`
`
`
`
`
`SOLAS OLED LTD.,
`
`
`
`v.
`GOOGLE LLC,
`
`
`
`
`
`SOLAS OLED LTD.,
`
`
`
`v.
`APPLE INC.,
`
`
`
`
`
`SOLAS OLED LTD.,
`
`
`
`v.
`HP INC.,
`
`
`
`Plaintiff,
`
`Defendant.
`
`Plaintiff,
`
`Defendant.
`
`Plaintiff,
`
`Defendant.
`
`Plaintiff,
`
`Defendant
`
`
`
`Case No. 6:19-cv-00514-ADA
`
`
`
`
`
`Case No. 6:19-cv-00515-ADA
`
`
`
`
`
`Case No. 6:19-cv-00537-ADA
`
`
`
`
`
`Case No. 6:19-cv-00631-ADA
`
`
`
`
`
`
`
`DECLARATION OF PHILIP X. WANG IN SUPPORT OF
`SOLAS’S OPENING CLAIM CONSTRUCTION BRIEF
`
`1
`
`
`
`Case 6:19-cv-00537-ADA Document 48-1 Filed 06/25/20 Page 2 of 4
`
`DECLARATION OF PHILIP X. WANG
`
`I, Philip X. Wang, declare as follows:
`
`1.
`
`I am a member of the State Bar of California and a partner at the law firm of Russ
`
`August & Kabat, counsel for Plaintiff Solas OLED Ltd. in the above-captioned action. I have
`
`personal knowledge of the facts set forth herein and, if called upon to testify, could and would
`
`testify competently thereto.
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of Declaration of Richard
`
`A. Flasck in support of Solas’s opening claim construction brief.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`Attached hereto as Exhibit 2 is a true and correct copy of U.S. Patent No. 6,072,450.
`
`Attached hereto as Exhibit 3 is a true and correct copy of U.S. Patent No. 7,447,338.
`
`Attached hereto as Exhibit 4 is a true and correct copy of U.S. Patent No. 7,573,068.
`
`Attached hereto as Exhibit 5 is a true and correct copy of U.S. Patent No. 7,499,042.
`
`Attached hereto as Exhibit 6 is a true and correct copy of U.S. Patent No. 7,663,615.
`
`Attached hereto as Exhibit 7 is a true and correct copy of the Parties’ joint revised
`
`list of terms/constructions dated June 12, 2020.
`
`9.
`
`Attached hereto as Exhibit 8 is a true and correct copy of The Authoritative
`
`Dictionary of IEEE Standards Terms (7th ed. 2000) (“IEEE Dictionary”), definitions of “drain,”
`
`“source,” select,” and “substrate.”
`
`10.
`
`Attached hereto as Exhibit 9 is a true and correct copy of Microsoft Computer
`
`Dictionary (3rd ed., 1997), definition of “signal” and ‘scan line.”
`
`11.
`
`Attached hereto as Exhibit 10 is a true and correct copy of McGraw-Hill Dictionary
`
`of Scientific and Technical Terms (4th ed., 1989), definitions of “data transmission line,” “source,”
`
`drain,” and “selection circuit.”
`
`
`
`2
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`
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`Case 6:19-cv-00537-ADA Document 48-1 Filed 06/25/20 Page 3 of 4
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`12.
`
`Attached hereto as Exhibit 11 is a true and correct copy of Merriam-Webster
`
`Dictionary (avail. at www.merriam-webster.com, accessed May 2020), definitions of “select,”
`
`“selection,” “sequential,” and “series.”
`
`13.
`
`Attached hereto as Exhibit 12 is a true and correct copy of Dictionary.com (avail.
`
`at www.dictionary.com, accessed May 2020), definitions of “period,” “section,” “sequence,” and
`
`“sequential.”
`
`14.
`
`Attached hereto as Exhibit 13 is a true and correct copy of Oxford Concise
`
`Dictionary (12th ed., 2011), definitions of “period” and “section.”
`
`15.
`
`Attached hereto as Exhibit 14 is a true and correct copy of Claim Construction
`
`Memorandum and Order from Solas OLED Ltd. v. Samsung Display Co., Ltd., 2:19-CV-00152-
`
`JRG, Dkt. 99 (E.D. Tex. Apr. 17, 2020).
`
`16.
`
`Attached hereto as Exhibit 15 is a true and correct copy of Claim Construction
`
`Order from Solas OLED Ltd. v. LG Display Co., LG Elec., Inc., and Sony Corp., Dkt. 82, Case
`
`6:19-cv-00236-ADA (W.D. Tex. June 9, 2020).
`
`17.
`
`Attached hereto as Exhibit 16 is a true and correct copy of the Parties’ Joint Claim
`
`Construction Statement from Solas OLED Ltd. v. LG Display Co., LG Elec., Inc., and Sony Corp.,
`
`Dkt. 76, Case 6:19-cv-00236-ADA (W.D. Tex. May 1, 2020).
`
`18.
`
`Attached hereto as Exhibit 17 is a true and correct copy of HP’s proposed claim
`
`constructions, served May 22, 2020.
`
`19.
`
`Attached hereto as Exhibit 18 is a true and correct copy of Plaintiff Solas OLED
`
`Limited’s Disclosure of Asserted Claims and Infringement Contentions, Case No. 2:19-cv-00152-
`
`JRG (E.D. Texas), served on Oct. 7, 2019.
`
`
`
`3
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`
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`Case 6:19-cv-00537-ADA Document 48-1 Filed 06/25/20 Page 4 of 4
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`20.
`
`Attached hereto as Exhibit 19 is a true and correct copy of Apple’s proposed terms
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`for construction, Case No. 6:19-cv-00537-ADA, served on April 30, 2020.
`
`21.
`
`Attached hereto as Exhibit 20 is a true and correct copy of Apple’s proposed claim
`
`constructions, Case No. 6:19-cv-00537-ADA, served on May 22, 2020.
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`22.
`
`Attached hereto as Exhibit 21 is a true and correct copy of excerpts from the
`
`transcript of the April 14, 2020, Telephonic Motion Hearing from Solas v. Dell and Google, Case
`
`Nos. 6:19-cv-00514-ADA, 6:19-cv-00515-ADA.
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`23.
`
`Attached hereto as Exhibit 22 is a true and correct copy of excerpts from The New
`
`Oxford American Dictionary, Second Edition (2005).
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`24.
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed
`
`this twenty-fifth day of June, 2020, at Los Angeles, California.
`
`
`
`
`
`
`
`
`/s/ Philip X. Wang
`Philip X. Wang
`
`
`
`
`
`4
`
`
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