`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`Plaintiff,
`
`
`Defendant.
`
`Plaintiff,
`
`
`Defendant.
`
`Plaintiff,
`
`
`Defendant.
`
`STRATOSAUDIO INC.,
`
`
`v.
`
`HYUNDAI MOTOR AMERICA,
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`
`
`STRATOSAUDIO INC.,
`
`
`v.
`
`MAZDA MOTOR OF AMERICA, INC.,
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`
`
`STRATOSAUDIO INC.,
`
`
`v.
`
`SUBARU OF AMERICA, INC.
`
`
`
`STRATOSAUDIO INC.,
`
`Plaintiff,
`
`
`v.
`VOLVO CARS USA, LLC,
`
`
`
`STRATOSAUDIO INC.,
`
`
`v.
`
`VOLKSWAGEN GROUP OF
`AMERICA, INC.,
`
`Defendant.
`
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`SECOND DECLARATION OF ROBERT GROSELAK IN SUPPORT OF
`DEFENDANTS’ REPLY CLAIM CONSTRUCTION BRIEF
`
`Case No. 6:20-CV-01125-ADA
`
`Case No. 6:20-cv-1126-ADA
`
`Case No. 6:20-cv-1128-ADA
`
`Case No. 6:20-cv-1129-ADA
`
`Case No. 6:20-CV-01131-ADA
`
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`
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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
`
`
`
`I, Robert B. Groselak, declare:
`
`1. I am an associate with the law firm of DLA Piper LLP (US), counsel of record for
`
`Defendants Mazda Motor Of America, Inc. (“Mazda”) and Subaru Of America, Inc.
`
`(“Subaru”). I have personal knowledge of the facts set forth in this declaration and, if
`
`called as a witness, could and would testify competently to these facts under oath.
`
`2. Attached to this declaration as Exhibit B (“Ex. B”) is a true and correct copy of the
`
`transcript of the deposition of Dr. William Mangione-Smith, Ph.D., Plaintiff’s expert
`
`witness. The deponent was located in Kirkland, Washington, and the deposition was
`
`taken via Zoom by all Defendants on September 17, 2021.
`
`3. Attached to this declaration as Exhibit C (“Ex. C”) is a true and correct copy of excerpts
`
`from the transcript of the deposition of Dr. Berry P. Medoff, Ph.D., one of Defendants’
`
`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.
`
`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.
`
`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.
`
`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
`
`Books Ngram Viewer for the term “stream analysis module”.
`
`
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`1
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`
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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.
`
`This exhibit is a true and correct copy of a PDF printed from the web-based Google
`
`Books Ngram Viewer for the term “stream scanner module”.
`
`8. Attached to this declaration as Exhibit H (“Ex. H”) is a true and correct copy of Exhibit
`
`0007 from the deposition of Dr. William Mangione-Smith taken on September 17, 2021.
`
`This exhibit is a true and correct copy of a PDF printed from the web-based Google
`
`Books Ngram Viewer for the term “broadcast scanning module”.
`
`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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`
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`Executed on September 20, 2021 in Chicago, IL.
`
`Robert B. Groselak
`Robert B. Groselak
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`2
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