`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`TOUCHSTREAM TECHNOLOGIES, INC.
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC
`
`Defendant.
`
`Civil Action No. 6:21-cv-569-ADA
`
`JURY TRIAL DEMANDED
`
`DECLARATION OF RYAN D. DYKAL IN SUPPORT OF
`TOUCHSTREAM’S REPLY IN SUPPORT OF ITS MOTION TO EXCLUDE
`EXPERT TESTIMONY OF DR. KETAN MAYER-PATEL
`
`I, Ryan D. Dykal, declare the following:
`
`1.
`
`I am a partner 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 Reply in Support of its Motion to Exclude Expert Testimony of Dr. Ketan Mayer-
`
`Patel. I am admitted pro hac vice in this matter. I am not a party to this action or proceeding.
`
`2.
`
`Unless otherwise noted, all of the facts stated herein are based on my own personal
`
`knowledge, as well as facts reasonably available to me. If called upon to testify as a witness, I
`
`could and would provide testimony competently under oath.
`
`3.
`
`Filed under seal as Exhibit 1 to Touchstream’s Motion to Exclude Expert
`
`Testimony of Dr. Ketan Mayer-Patel is a true and accurate copy of excerpts from the Expert Report
`
`of Dr. Ketan Mayer-Patel Regarding Invalidity of U.S. Patent Nos. 8,356,251, 8,782,528, and
`
`8,904,289, served on November 11, 2022.
`
`1
`
`
`
`Case 6:21-cv-00569-ADA Document 183 Filed 01/19/23 Page 2 of 2
`
`4.
`
`Filed under seal as Exhibit 2 to Touchstream’s Motion to Exclude Expert
`
`Testimony of Dr. Ketan Mayer-Patel is a true and accurate copy of excerpts of the Deposition of
`
`Dr. Ketan Mayer-Patel, conducted virtually on December 13, 2022.
`
`5.
`
`Filed under seal as Exhibit 3 to Touchstream’s Motion to Exclude Expert
`
`Testimony of Dr. Ketan Mayer-Patel is a true and accurate copy of GTS-22, a prior art reference
`
`Dr. Mayer-Patel relied upon in his expert report.
`
`6.
`
`Filed under seal as Exhibit 4 to Touchstream’s Motion to Exclude Expert
`
`Testimony of Dr. Ketan Mayer-Patel is a true and accurate copy of GTS-24, a prior art reference
`
`Dr. Mayer-Patel relied upon in his expert report.
`
`7.
`
`Filed under seal as Exhibit 7 to Touchstream’s Motion to Exclude Expert
`
`Testimony of Dr. Ketan Mayer-Patel is a true and accurate copy of an excerpt of Dr. Ketan Mayer-
`
`Patel’s expert report, as compared in redline to Defendant’s Final Invalidity Contentions.
`
`8.
`
`I declare under penalty of perjury under the laws of the United States that the
`
`foregoing is true and correct.
`
`Executed on January 19, 2023 in Kansas City, Missouri.
`
`By: /s/ Ryan Dykal
`Ryan Dykal
`Shook, Hardy & Bacon L.L.P.
`2555 Grand Boulevard
`Kansas City, MO 64108
`
`Attorney for Plaintiff Touchstream
`Technologies, Inc.
`
`2
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
