`
`
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff
`
`v.
`
`GOOGLE LLC,
`
`Defendants.
`
`
`
`CASE NO. 6:21-cv-667-ADA
`
`JURY TRIAL DEMANDED
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`
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`DECLARATION OF ROBERT W. UNIKEL IN SUPPORT OF DEFENDANT
`GOOGLE LLC’S OPPOSED MOTION TO TRANSFER
`
`I, Robert W. Unikel, declare as follows:
`
`1.
`
`I am an attorney with the law firm Paul Hastings LLP and counsel for Defendant
`
`Google LLC (“Google”). I have personal knowledge of the facts contained in the declaration and,
`
`if called upon to do so, I could and would testify competently to the matters set forth herein.
`
`2.
`
`VoIP-Pal.com, Inc. (“VoIP-Pal”) asserted U.S. Patent Nos. 8,630,234 (“the ’234
`
`Patent”) and 10,880,721 (“the ’721 Patent”) (collectively, the “Asserted Patents”) against Google,
`
`T-Mobile US Inc., Cellco Partnership (d/b/a Verizon Wireless), AT&T Corp., Apple Inc.,
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`Amazon.com Inc., and Facebook Inc.
`
`3.
`
`Verizon, Apple, and AT&T filed Declaratory Judgment actions on the Asserted
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`Patents in the Northern District of California, which were assigned to Judge James Donato. See
`
`Exhibit A, summarizing the waves of litigations brought by VoIP-Pal.
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`4.
`
`Attached hereto as Exhibit A is a table summarizing the waves of cases brought by
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`VoIP-Pal against various defendants.
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`-1-
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`
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`Case 6:21-cv-00667-ADA Document 26 Filed 11/11/21 Page 2 of 4
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`
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`filing.
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`5.
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`6.
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`10,218,606.
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`7.
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`8.
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`9.
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`Attached hereto as Exhibit B is a true and correct copy of VoIP-Pal’s form 10-K
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`Attached hereto as Exhibit C is a true and correct copy of U.S. Patent No.
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`Attached hereto as Exhibit D is a true and correct copy of the ’234 Patent.
`
`Attached hereto as Exhibit E is a true and correct copy of the ’721 Patent.
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`Johan Emil Viktor Björsell is a named inventor on all of the patents from this case
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`and the prior waves (summarized in Exhibit A).
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`10.
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`VoIP-Pal alleges that particular functionalities of Google Fi and Google Hangouts
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`infringe the Asserted Patents.
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`11.
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`Attached hereto as Exhibit F is a true and correct copy of the website for “Virtual
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`office Waco Location” located at 7215 Bosque Blvd. Waco, TX 76710.
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`12.
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`Attached hereto as Exhibit G is a true and correct copy of a LexisNexis Public
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`Records: SmartLinx Comprehensive Business report for the street address 7215 Bosque Blvd.
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`Waco, TX 76710.
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`13.
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`Attached hereto as Exhibit H is a true and correct copy of an S&P Global Market
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`Intelligence report regarding the VoIP-Pal board members.
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`14.
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`Attached hereto as Exhibit I is a true and correct copy of a screenshot of an article
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`on the Dialpad webpage, describing the Dialpad prior art.
`
`15.
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`Attached hereto as Exhibit J is a true and correct copy of a screenshot of an article
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`“Have Number Will Travel” describing the GrandCentral prior art.
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`16.
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`Attached hereto as Exhibit K is a true and correct copy of a press release from July
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`3, 2007 entitled “Google acquires Web-calling service GrandCentral”.
`
`-2-
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`
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`Case 6:21-cv-00667-ADA Document 26 Filed 11/11/21 Page 3 of 4
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`
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`17.
`
`Attached hereto as Exhibit L is a true and correct copy of the LinkedIn profile for
`
`Craig Walker, listing his location as San Francisco, California.
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`18.
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`Attached hereto as Exhibit M is a true and correct copy of the LinkedIn profile for
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`Vincent Paquet, listing his location as San Francisco Bay Area.
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`19.
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`Attached hereto as Exhibit N is a true and correct copy of Cub Club Inv., LLC v.
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`Apple, Inc., No. 6:20-cv-00856-ADA, Dkt. 28.
`
`20.
`
`Attached hereto as Exhibit O is a true and correct copy of Google flights from
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`Stockholm, Sweden to San Francisco, California sorted by duration.
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`21.
`
`Attached hereto as Exhibit P is a true and correct copy of Google flights from
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`Stockholm, Sweden to Waco, Texas sorted by duration.
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`22.
`
`Attached hereto as Exhibit Q is a true and correct copy of an “Overview for Alan
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`D. Albright of W.D. Tex.” from Lex Machina.
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`23.
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`Attached hereto as Exhibit R is a true and correct copy of an “Overview for N.D.
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`Cal.” from Lex Machina.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed this 11
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`day of November in Chicago, Illinois.
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`
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`
`
`
`
`
`
`/s/ Robert W. Unikel
`Robert W. Unikel
`
`
`
`-3-
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`
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`Case 6:21-cv-00667-ADA Document 26 Filed 11/11/21 Page 4 of 4
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`
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`CERTIFICATE OF SERVICE
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`Pursuant to the Federal Rules of Civil Procedure and Local Rule CV-5, I hereby certify
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`that, on November 11, 2021, all counsel of record who have appeared in these cases are being
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`served with a copy of the foregoing via the Court’s CM/ECF system.
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`
`
` /s/ Paige Arnette Amstutz
`Paige Arnette Amstutz
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`
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`-4-
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