`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`
`
`
`CIVIL ACTION NO. 6:21-cv-667-ADA
`
`
`
`
`
`
`
`CIVIL ACTION NO. 6:21-cv-668-ADA
`
`
`
`
`
`
`CIVIL ACTION NO. 6:21-cv-665-ADA
`
`
`
`
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`AMAZON.COM, INC.;
`AMAZON.COM SERVICES LLC; and
`AMAZON WEB SERVICES, INC.,
`
`Defendants.
`
`
`
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff,
`
`v.
`
`FACEBOOK, INC. and WHATSAPP, INC.,
`
`Defendants.
`
`
`
`DECLARATION OF LEWIS E. HUDNELL III IN SUPPORT OF
`PLAINTIFF VOIP-PAL.COM, INC.’S OPPOSITION TO DEFENDANTS’
`OPPOSED MOTION TO STAY
`
`I, Lewis E. Hudnell, III, declare as follows:
`
`
`
`
`
`
`
`
`
`
`
`Case 6:21-cv-00667-ADA Document 14-1 Filed 08/19/21 Page 2 of 3
`
`1.
`
`I am the founding principal of Hudnell Law Group P.C., counsel for VoIP-Pal and
`
`I am admitted to the Bar of this Court. I have personal knowledge of the facts in this declaration,
`
`and if called as a witness, I could and would testify competently regarding those facts.
`
`2.
`
`Attached to my declaration as Exhibit 1 is a true and correct copy of the Order
`
`Relating Cases issued on April 27, 2020 in Case No. 18-cv-06217-LHK, in the U.S. District
`
`Court for the Northern District of California.
`
`3.
`
`Attached to my declaration as Exhibit 2 is a true and correct copy of the Order
`
`Relating Cases issued on May 22, 2020 in Case No. 18-cv-06177-LHK, in the U.S. District
`
`Court for the Northern District of California.
`
`4.
`
`Attached to my declaration as Exhibit 3 is a true and correct copy of the Order
`
`Relating Cases issued on May 26, 2020 in Case No. 18-cv-06054-LHK, in the U.S. District
`
`Court for the Northern District of California.
`
`5.
`
`Attached to my declaration as Exhibit 4 is a true and correct copy of the Order
`
`Staying Cases issued on September 29, 2020 in Case Nos. 5:20-cv-02397, 5:20-cv-02460, 5:20-
`
`cv-02995, and 5:20-cv-03092 in the U.S. District Court for the Western District of Texas.
`
`6.
`
`Attached to my declaration as Exhibit 5 is a true and correct copy of the Order
`
`Reassigning Case issued on July 20, 2021 in Case No. 21-cv-05110-BLF, in the U.S. District
`
`Court for the Northern District of California.
`
`7.
`
`Attached to my declaration as Exhibit 6 is a true and correct copy of the Order
`
`Reassigning Case issued on July 15, 2021 in Case No. 21-cv-05078-SK, in the U.S. District
`
`Court for the Northern District of California.
`
`
`
`- 2 -
`
`
`
`Case 6:21-cv-00667-ADA Document 14-1 Filed 08/19/21 Page 3 of 3
`
`8.
`
`Attached to my declaration as Exhibit 7 is a true and correct copy of the Order
`
`Reassigning Case issued on July 26, 2021 in Case No. 21-cv-05275-JCS, in the U.S. District
`
`Court for the Northern District of California.
`
`9.
`
`Attached to my declaration as Exhibit 8 is a true and correct copy of a comparison
`
`chart of the claims of the ’234 and ’721 patents versus claims of VoIP-Pal patents from the RBR
`
`patent family.
`
`10.
`
`Attached to my declaration as Exhibit 9 is a true and correct copy of a comparison
`
`chart of the abstract of the ’234 and ’721 patents versus abstract of another VoIP-Pal patent from
`
`the RBR patent family.
`
`11.
`
`Attached to my declaration as Exhibit 10 is a true and correct copy of a Request for
`
`Motion Hearing dated March 24, 2021 in the 2020 NDCAL actions.
`
`12.
`
`Attached to my declaration as Exhibit 11 is a true and correct copy of a Request for
`
`Motion Hearing dated June 16, 2021 in the 2020 NDCAL actions.
`
`13.
`
`Exhibits 10-11 are the last two motion hearing requests that I have made in the 2020
`
`NDCAL cases. Exhibit 10 set the hearing date for July 22, 2021—almost four months after the
`
`motion was filed. The motion is fully briefed and as of today, Judge Koh has not decided the
`
`motion. Exhibit 11 set the hearing date for October 21, 2021—over four months after the motion
`
`was filed. The motion is fully briefed and as of today, Judge Koh has not decided the motion.
`
`Under 28 U.S.C. § 1746, I, Lewis E. Hudnell, III, declare under penalty of perjury that
`
`the foregoing is true and correct.
`
`
`
`
`
`
`
`
`
`Executed on this 19th day of August 2021, in Mountain View, California.
`
`
`
`
`/s/ Lewis E. Hudnell, III
` Lewis E. Hudnell, III
`
`
`
`
`
`- 3 -
`
`
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
