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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Plaintiff,
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`Defendant.
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`Plaintiff,
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`Defendant.
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`Plaintiff,
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`Defendant.
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`STRATOSAUDIO INC.,
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`v.
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`HYUNDAI MOTOR AMERICA,
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`STRATOSAUDIO INC.,
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`v.
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`MAZDA MOTOR OF AMERICA, INC.,
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`STRATOSAUDIO INC.,
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`v.
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`SUBARU OF AMERICA, INC.
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`STRATOSAUDIO INC.,
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`Plaintiff,
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`v.
`VOLVO CARS USA, LLC,
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`STRATOSAUDIO INC.,
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`v.
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`VOLKSWAGEN GROUP OF
`AMERICA, INC.,
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`Defendant.
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`SECOND DECLARATION OF ROBERT GROSELAK IN SUPPORT OF
`DEFENDANTS’ REPLY CLAIM CONSTRUCTION BRIEF
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`Case No. 6:20-CV-01125-ADA
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`Case No. 6:20-cv-1126-ADA
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`Case No. 6:20-cv-1128-ADA
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`Case No. 6:20-cv-1129-ADA
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`Case No. 6:20-CV-01131-ADA
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`Defendant.
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`Plaintiff,
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`Case 6:20-cv-01131-ADA Document 57-1 Filed 09/20/21 Page 2 of 3
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`I, Robert B. Groselak, declare:
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`1. I am an associate with the law firm of DLA Piper LLP (US), counsel of record for
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`Defendants Mazda Motor Of America, Inc. (“Mazda”) and Subaru Of America, Inc.
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`(“Subaru”). I have personal knowledge of the facts set forth in this declaration and, if
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`called as a witness, could and would testify competently to these facts under oath.
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`2. Attached to this declaration as Exhibit B (“Ex. B”) is a true and correct copy of the
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`transcript of the deposition of Dr. William Mangione-Smith, Ph.D., Plaintiff’s expert
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`witness. The deponent was located in Kirkland, Washington, and the deposition was
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`taken via Zoom by all Defendants on September 17, 2021.
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`3. Attached to this declaration as Exhibit C (“Ex. C”) is a true and correct copy of excerpts
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`from the transcript of the deposition of Dr. Berry P. Medoff, Ph.D., one of Defendants’
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`expert witnesses. The deponent was located in Palo Alto, CA, and the deposition was
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`taken via Zoom by Plaintiff on August 30, 2021.
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`4. Attached to this declaration as Exhibit D (“Ex. D”) is a true and correct copy of a PDF
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`printed from the web-based Google Books Ngram Viewer for the term “interactive media
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`receiver” as last viewed on September 20, 2021 at 9:11 AM PDT.
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`5. Attached to this declaration as Exhibit E (“Ex. E”) is a true and correct copy of a PDF
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`printed from the web-based Google Books Ngram Viewer for the term “responder
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`identifier” as last viewed on September 20, 2021 at 9:12 AM PDT.
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`6. Attached to this declaration as Exhibit F (“Ex. F”) is a true and correct copy of Exhibit
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`0005 from the deposition of Dr. William Mangione-Smith taken on September 17, 2021.
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`This exhibit is a true and correct copy of a PDF printed from the web-based Google
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`Books Ngram Viewer for the term “stream analysis module”.
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`1
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`Case 6:20-cv-01131-ADA Document 57-1 Filed 09/20/21 Page 3 of 3
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`7. Attached to this declaration as Exhibit G (“Ex. G”) is a true and correct copy of Exhibit
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`0006 from the deposition of Dr. William Mangione-Smith taken on September 17, 2021.
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`This exhibit is a true and correct copy of a PDF printed from the web-based Google
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`Books Ngram Viewer for the term “stream scanner module”.
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`8. Attached to this declaration as Exhibit H (“Ex. H”) is a true and correct copy of Exhibit
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`0007 from the deposition of Dr. William Mangione-Smith taken on September 17, 2021.
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`This exhibit is a true and correct copy of a PDF printed from the web-based Google
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`Books Ngram Viewer for the term “broadcast scanning module”.
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`9. Attached to this declaration as Exhibit I (“Ex. I”) is a true and correct copy of Exhibit
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`0008 from the deposition of Dr. William Mangione-Smith taken on September 17, 2021.
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`This exhibit is a true and correct copy of excerpts from an Office Action during the
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`prosecution of U.S. Application Number 15/404,075, which is a continuation of, inter
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`alia, 9,584,843 and 9,294,806, two of the patents-in-suit.
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`10. Attached to this declaration as Exhibit J (“Ex. J”) is a true and correct copy of excerpts
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`from the transcript of the deposition of Dr. Tim A. Williams, Ph.D., one of Defendants’
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`expert witnesses. The deponent was located in Danville, CA, and the deposition was
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`taken via Zoom by Plaintiff on August 27, 2021.
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`I declare under penalty of perjury under the laws of the State of Texas and the United
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`States of America that the foregoing is true and correct.
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`Executed on September 20, 2021 in Chicago, IL.
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`Robert B. Groselak
`Robert B. Groselak
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`2
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