`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`TOUCHSTREAM TECHNOLOGIES, INC.,
`
`
`Plaintiff,
`
`
`
`v.
`
`
`GOOGLE LLC,
`
`
`Defendant.
`
`Civil Case No. 6:21-cv-569-ADA
`
`JURY TRIAL DEMANDED
`
`U.S. District Judge Alan Albright
`
`
`
`DECLARATION OF JUSTIN R. DONOHO IN SUPPORT OF TOUCHSTREAM’S
`MOTION TO EXCLUDE CERTAIN OPINIONS AND TESTIMONY
`OF DEFENDANT’S DAMAGES EXPERT CHRISTOPHER A. MARTINEZ
`
`I, Justin R. Donoho, declare the following:
`
`1.
`
`I am Senior Counsel at the law firm of Shook, Hardy & Bacon L.L.P., attorneys for
`
`Plaintiff, Touchstream Technologies, Inc. (“Touchstream”). I make this declaration in support of
`
`Touchstream’s Motion to Exclude Certain Opinions and Testimony of Defendant’s Damages
`
`Expert Christopher A. Martinez. I am admitted pro hac vice in this matter.
`
`2.
`
`In accordance with this Court’s Standing Order Governing Proceedings (“OGP”)
`
`4.2—Patent Cases, Section X(11), I have caused to be highlighted the relied upon sections of
`
`Exhibits 1, 2, and 3 accompanying Touchstream’s motion.
`
`I state under penalty of perjury that the foregoing is true and correct to the best of my
`
`knowledge, information, and belief.
`
`Executed on December 29, 2022 in Chicago, Illinois.
`
`
`
`
`
`
`
`
`
`By: /s/ Justin R. Donoho
`Justin R. Donoho
`Shook, Hardy & Bacon L.L.P.
`111 South Wacker Drive, Suite 4700
`Chicago, IL 60606
`T: (312) 704-7700 / jdonoho@shb.com
`Attorney for Plaintiff Touchstream Technologies, Inc.
`
`
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