Case 6:20-cv-01216-ADA Document 41-31 Filed 10/06/21 Page 1 of 4
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`MEDIATEK INC., ET AL.,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`NVIDIA CORPORATION,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`NXP SEMICONDUCTORS NV, ET AL.,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`RENESAS ELECTRONICS CORPORATION, ET AL.,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`SILICON LABORATORIES INC.,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`STMICROELECTRONICS INC.,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`WESTERN DIGITAL TECHNOLOGIES, INC.,
`Defendant.
`
`
`
`
`Case No. 6:20-cv-01210-ADA
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`
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`Case No. 6:20-cv-01211-ADA
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`
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`Case No. 6:20-cv-01212-ADA
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`
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`Case No. 6:20-cv-01213-ADA
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`
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`Case No. 6:20-cv-01214-ADA
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`Case No. 6:20-cv-01215-ADA
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`Case No. 6:20-cv-01216-ADA
`
`STEPHANIE SIVINSKI’S DECLARATION IN SUPPORT OF DEFENDANTS’
`OPENING CLAIM CONSTRUCTION BRIEF
`
`
`
`
`
`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`MEDIATEK INC., ET AL.,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`NVIDIA CORPORATION,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`NXP SEMICONDUCTORS NV, ET AL.,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`RENESAS ELECTRONICS CORPORATION, ET AL.,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`SILICON LABORATORIES INC.,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`STMICROELECTRONICS INC.,
`Defendant.
`
`OCEAN SEMICONDUCTOR LLC,
`
`Plaintiff,
`vs.
`WESTERN DIGITAL TECHNOLOGIES, INC.,
`Defendant.
`
`
`
`
`Case No. 6:20-cv-01210-ADA
`
`
`
`Case No. 6:20-cv-01211-ADA
`
`
`
`Case No. 6:20-cv-01212-ADA
`
`
`
`Case No. 6:20-cv-01213-ADA
`
`
`
`Case No. 6:20-cv-01214-ADA
`
`
`
`Case No. 6:20-cv-01215-ADA
`
`
`
`Case No. 6:20-cv-01216-ADA
`
`STEPHANIE SIVINSKI’S DECLARATION IN SUPPORT OF DEFENDANTS’
`OPENING CLAIM CONSTRUCTION BRIEF
`
`
`
`
`
`
`
`
`Case 6:20-cv-01216-ADA Document 41-31 Filed 10/06/21 Page 2 of 4
`
`I, Stephanie Sivinski, declare and state as follows:
`
`1.
`
`2.
`
`I am an attorney admitted to practice in the State of Texas.
`
`I am a partner at the law firm Haynes and Boone LLP and represent Defendants
`
`MediaTek, Inc. and MediaTek USA, Inc.
`
`3.
`
`I provide this declaration in support of the Defendants’ Opening Claim
`
`Construction Brief. If called to testify as a witness, I could and would competently do so under
`
`oath. Portions of certain attached exhibits have been highlighted for the Court’s convenience to
`
`indicate the relevant portions of that exhibit.
`
`4.
`
`5.
`
`6.
`
`7.
`
`8.
`
`9.
`
`10.
`
`11.
`
`12.
`
`13.
`
`14.
`
`15.
`
`16.
`
`17.
`
`18.
`
`Attached as Exhibit 1 is a true and correct copy of U.S. Patent No. 6,420,097.
`
`Attached as Exhibit 2 is a true and correct copy of U.S. Patent No. 6,660,651.
`
`Attached as Exhibit 3 is a true and correct copy of U.S. Patent No. 7,080,330.
`
`Attached as Exhibit 4 is a true and correct copy of U.S. Patent No. 8,676,538.
`
`Attached as Exhibit 5 is a true and correct copy of U.S. Patent No. 6,907,305.
`
`Attached as Exhibit 6 is a true and correct copy of U.S. Patent No. 6,968,248.
`
`Attached as Exhibit 7 is a true and correct copy of U.S. Patent No. 6,127,070.
`
`Attached as Exhibit 8 is a true and correct copy of U.S. Patent No. 6,140,023.
`
`Attached as Exhibit 9 is a true and correct copy of U.S. Patent No. 6,309,926.
`
`Attached as Exhibit 10 is a true and correct copy of U.S. Patent No. 6,162,587.
`
`Attached as Exhibit 11 is a true and correct copy of U.S. Patent No. 6,165,695.
`
`Attached as Exhibit 12 is a true and correct copy of U.S. Patent No. 6,762,133.
`
`Attached as Exhibit 13 is a true and correct copy of U.S. Patent No. 6,645,702.
`
`Attached as Exhibit 14 is a true and correct copy of U.S. Patent No. 6,746,973.
`
`Attached as Exhibit 15 is a true and correct copy of U.S. Patent No. 6,451,512.
`
`1
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`
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`Case 6:20-cv-01216-ADA Document 41-31 Filed 10/06/21 Page 3 of 4
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`19.
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`20.
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`21.
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`22.
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`Attached as Exhibit 16 is a true and correct copy of U.S. Patent No. 6,156,480.
`
`Attached as Exhibit 17 is a true and correct copy of U.S. Patent No. 6,566,214.
`
`Attached as Exhibit 18 is a true and correct copy of U.S. Patent No. 6,326,319.
`
`Attached as Exhibit 19 is a true and correct copy of the definition of “pneumatic”
`
`in the American Heritage Dictionary, Fourth Edition, published in 2004.
`
`23.
`
`Attached as Exhibit 20 is a true and correct copy of the definition of “pneumatic”
`
`in Dictionary of Engineering, published in 1997.
`
`24.
`
`Attached as Exhibit 21 is a true and correct copy of the definition of “pneumatic”
`
`in Merriam-Webster’s Collegiate Dictionary, Tenth Edition, published in 1998 and bearing a
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`copyright of 2001.
`
`25.
`
`Attached as Exhibit 22 is a true and correct copy of an excerpt of “Pneumatic
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`Systems, Principles and Maintenance” by S. J. Majumdar, published in 1995.
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`26.
`
`Attached as Exhibit 23 is a true and correct copy of Exhibit H to the Complaint in
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`Ocean Semiconductor LLC v. Western Digital Techs., No. 6:20-CV-1216 (W.D. Tex. Dec. 31,
`
`2020), Dkt. 1-8. This exhibit is representative of Ocean’s infringement positions in all of the
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`above-captioned cases.
`
`27.
`
`Attached as Exhibit 24 is a true and correct copy of Appendix A1 to Plaintiff’s
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`Preliminary Infringement Contentions in Ocean Semiconductor LLC v. Western Digital Techs.,
`
`No. 6:20-CV-1216 (W.D. Tex. Dec. 31, 2020). This exhibit is representative of Ocean’s
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`infringement positions in all of the above-captioned cases.
`
`28.
`
`Attached as Exhibit 25 is a true and correct copy of applicant’s appeal brief dated
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`November 24, 2004 in the file history of U.S. Patent No. 6,907,305.
`
`29.
`
`Attached as Exhibit 26 is a true and correct copy of applicant’s response dated
`
`2
`
`
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`Case 6:20-cv-01216-ADA Document 41-31 Filed 10/06/21 Page 4 of 4
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`September 8, 2003 in the file history of U.S. Patent No. 6,907,305.
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`30.
`
`Attached as Exhibit 27 is a true and correct copy of applicant’s response dated
`
`August 6, 2004 in the file history of U.S. Patent No. 6,907,305.
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`31.
`
`Attached as Exhibit 28 is a true and correct copy of the definition of “concurrent”
`
`in Chambers Dictionary, New Ninth Edition, published in 2003.
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`32.
`
`Attached as Exhibit 29 is a true and correct copy of the definition of “concurrent”
`
`in Webster’s Unabridged Dictionary, Second Edition, published in 2001.
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`33.
`
`Attached as Exhibit 30 is a true and correct copy of Ocean Semiconductor’s
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`Patent Owner’s Preliminary Response to Western Digital’s IPR on U.S. Patent No. 7,080,330,
`
`dated August 26, 2021.
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`I declare under penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct.
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`
`
`
`Executed on October 6, 2021
`
`
`
`
`Stephanie Sivinski
`
`
`
`3
`
`
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