`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`VOIP-PAL.COM, INC.,
`Plaintiff,
`
`v.
`AMAZON.COM, INC.,
`AMAZON.COM SERVICES LLC, and
`AMAZON WEB SERVICES, INC.,
`Defendants.
`
`Civil Action No. 6:20-CV-00272-ADA
`
`DECLARATION OF DANIEL T. SHVODIAN IN SUPPORT OF
`AMAZON’S OPPOSITION TO VOIP-PAL’S MOTION TO LIFT STAY
`AND RESET MARKMAN HEARING DATE
`
`
`
`Case 6:20-cv-00272-ADA Document 80-1 Filed 01/26/23 Page 2 of 4
`
`I, Daniel T. Shvodian, declare:
`
`1.
`
`I am counsel for Amazon.com, Inc., Amazon.com Services LLC, and Amazon Web
`
`Services, Inc. (“Amazon”) in this case. I submit this Declaration in support of Amazon’s
`
`Opposition To VoIP-Pal’s Motion To Lift Stay and Reset Markman Hearing Date.
`
`2.
`
`Attached as Exhibit A is a true and correct copy of Defendant Google LLC’s Notice
`
`and Memorandum of Points and Authorities in Support of Its Motion for Judgment on the
`
`Pleadings.
`
`3.
`
`Attached as Exhibit B is a true and correct copy of Defendants Meta Platforms Inc.
`
`and WhatsApp LLC’s Notice and Memorandum of Points and Authorities in Support of Their
`
`Motion for Judgment on the Pleadings.
`
`4.
`
`In this litigation, VoIP-Pal has asserted claims 1, 3-6, 8-9, 11, 14-15, 18-24, 26-27,
`
`and 44 against Amazon. VoIP-Pal has asserted those same claims against Google, and Google’s
`
`motion for judgment on the pleadings addresses each of those claims. (See, e.g., Ex. A at 12, n.3.)
`
`5.
`
`Judge Donato of the Northern District of California held a status conference on
`
`January 26, 2023 in VoIP-Pal, Inc. v. Google LLC, Case No. 3:22-cv-05419-JD (N.D. Cal.), VoIP-
`
`Pal, Inc. v. Meta Platforms, Inc., Case No. 3:22-cv-04279-JD (N.D. Cal.), and related cases. An
`
`attorney from my firm attended that hearing, and I conferred with counsel for Google and Meta
`
`about the hearing. I was informed that Judge Donato held that VoIP-Pal had two weeks to file an
`
`answer to a related declaratory judgment complaint and that the parties seeking to invalidate the
`
`’606 patent under 35 U.S.C. section 101 would then have up to four weeks to file a consolidated
`
`motion for judgment on the pleadings. I was further informed that Judge Donato will rule on that
`
`motion, but that the cases pending in the Northern District of California will otherwise be stayed
`
`1
`
`
`
`Case 6:20-cv-00272-ADA Document 80-1 Filed 01/26/23 Page 3 of 4
`
`pending the resolution of the VoIP-Pal cases in the Western District of Texas if the motion for
`
`judgment on the pleadings is not granted.
`
`6.
`
`I conferred with counsel for Google and Meta and they intend to file a consolidated
`
`motion for judgment on the pleadings on or before the deadline set by Judge Donato.
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is
`
`true and correct.
`
`Dated: January 26, 2023
`
`
`
`/s/ Daniel T. Shvodian
`Daniel T. Shvodian
`
`2
`
`
`
`Case 6:20-cv-00272-ADA Document 80-1 Filed 01/26/23 Page 4 of 4
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true and correct copy of the above and foregoing
`
`document has been served January 26, 2023 to all counsel of record, via the Court’s CM/ECF
`
`system.
`
`/s/ Daniel T. Shvodian
`Daniel T. Shvodian
`
`
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