`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`DEMARAY LLC,
`
`
`
`
`Plaintiff,
`
`v.
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`Defendant.
`
`Plaintiff,
`
`
`INTEL CORPORATION
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`
`
`
`DEMARAY LLC,
`
`
`
`
`v.
`
`
`SAMSUNG ELECTRONICS CO., LTD,
`SAMSUNG ELECTRONICS AMERICA, INC.,
`SAMSUNG SEMICONDUCTOR, INC., and
`SAMSUNG AUSTIN SEMICONDUCTOR, LLC
`
`
`
`
`Defendants.
`
`Case No. 6:20-CV-00634-ADA
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`JURY TRIAL DEMANDED
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`Case No. 6:20-CV-00636-ADA
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`JURY TRIAL DEMANDED
`
`DECLARATION OF PHILIP OU IN SUPPORT OF DEFENDANTS’ CLAIM
`CONSTRUCTION BRIEF REGARDING ADDITIONAL TERMS FOR CLAIM 2 OF U.S.
`PATENT NO. 7,381,657
`
`I, Philip Ou, hereby declare as follows:
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`1. I am a partner with the law firm Paul Hastings LLP, counsel for Defendant Intel
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`Corporation (“Intel”) and Defendants Samsung Electronics Co., Ltd., Samsung Electronics
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`America, Inc., Samsung Semiconductor, Inc., Samsung Austin Semiconductor, LLC
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`(“Samsung”). I have personal knowledge of the facts contained in the declaration and, if called
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`upon to do so, I could and would testify competently to the matters set forth herein.
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`
`
`
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`Case 6:20-cv-00636-ADA Document 145-1 Filed 12/10/21 Page 2 of 2
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`
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`2. Attached hereto as Exhibit A is a true and correct copy of the hearing transcript for the
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`September 27, 2021 discovery hearing held in the above-captioned matters.
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`3. Attached hereto as Exhibit B is a true and correct copy of U.S. Patent No. 7,381,657.
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`4. Attached hereto as Exhibit C are true and correct excerpts of the file history for U.S.
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`Patent No. 7,381,657.
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`5. Attached hereto as Exhibit D are true and correct excerpts from Demaray LLC’s
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`February 5, 2021 infringement contentions against Intel. Given their designation under the
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`Agreed to Protective Order and that they contain Intel confidential information, Exhibit D is only
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`being filed in Demaray LLC v. Intel Corp., Case No. 6:20-cv-634-ADA and is being filed under
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`seal.
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`6. Attached hereto as Exhibit E are true and correct excerpts from Demaray LLC’s
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`February 5, 2021 infringement contentions against Samsung. Given their designation under the
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`Agreed to Protective Order and that they contain Samsung confidential information, Exhibit E is
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`only being filed in Demaray LLC v. Samsung Elecs. Co., Ltd., Case No. 6:20-cv-636-ADA and is
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`being filed under seal.
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`7. Attached hereto as Exhibit F is a true and correct copy of a document prepared for
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`demonstrative purposes depicting a timeline of true and correct excerpts of the file history for
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`U.S. Patent No. 7,381,657.
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`DATED: December 10, 2021
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`
`
`
`By: /s/ Philip Ou
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`Philip Ou
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`
`
`
`-2-
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`