`
`UNITED STATES DISTRICT COURT
`
`FOR THE WESTERN DISTRICT OF TEXAS
`
`WACO DIVISION
`
`ALMONDNET, INC.,
`
`Plaintiff,
`
`Case No. 6:21-cv-00898-ADA
`
`v.
`
`JURY TRIAL DEMANDED
`
`AMAZON.COM, INC.; AMAZON.COM
`SERVICES LLC; and AMAZON WEB
`SERVICES, INC.,
`
`Defendants.
`
`DECLARATION OF JAMES TSUEI IN SUPPORT OF
`PLAINTIFF’S RESPONSE TO DEFENDANTS’ MOTION FOR SUMMARY
`JUDGMENT OF NO WILLFUL INFRINGEMENT
`
`
`
`Case 6:21-cv-00898-ADA Document 159 Filed 09/07/23 Page 2 of 4
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`I, James Tsuei, declare and state as follows:
`
`1.
`
`I am a member of the State Bar of California, an attorney at the firm of Russ August
`
`& Kabat, and counsel of record for Plaintiff AlmondNet, Inc. in the above-captioned action. I
`
`submit this declaration in support of Plaintiff’s Response to Defendants’ Motion For Summary
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`Judgment of No Willful Infringement. I have personal knowledge of the facts set forth herein, and
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`if called upon to testify, could and would testify competently thereto.
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`2.
`
`Attached as Exhibit 1 is a true and correct copy of Plaintiff’s Second Supplemental
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`Objections and Responses to Defendants’ First Set of Interrogatories (Nos. 1-10, 12-13, 15), dated
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`February 10, 2023. This exhibit contains highlighting that I added, pursuant to General Issue 11
`
`of the OGP.
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`3.
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`Attached as Exhibit 2 is a true and correct copy of Defendants’ Responses and
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`Objections to Plaintiff’s First Set of Requests for Admission (Nos. 1–9), dated September 26,
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`2022. This exhibit contains highlighting that I added, pursuant to General Issue 11 of the OGP.
`
`4.
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`Attached as Exhibit 3 is a true and correct copy of the deposition transcript of Scott
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`Hayden, dated April 18, 2023. This exhibit contains highlighting that I added, pursuant to General
`
`Issue 11 of the OGP.
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`5.
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`Attached as Exhibit 4 is a true and correct copy of Defendants’ Omnibus
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`Supplemental Objections and Responses to Plaintiff’s First Set of Interrogatories (Nos. 1-27),
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`dated June 2, 2023. This exhibit contains highlighting that I added, pursuant to General Issue 11
`
`of the OGP.
`
`6.
`
`Attached as Exhibit 5 is a true and correct copy of the Notice of Patent Infringement
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`correspondence sent to CEO of Amazon.com Jeff Bezos from Ragnar Olson, dated July 24, 2019,
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`which was designated exhibit “Hayden 4” during the April 18, 2023 deposition of Scott Hayden
`
`
`
`1
`
`
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`Case 6:21-cv-00898-ADA Document 159 Filed 09/07/23 Page 3 of 4
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`and bears a stamp indicating the same. This exhibit contains highlighting that I added, pursuant to
`
`General Issue 11 of the OGP.
`
`7.
`
`Attached as Exhibit 6 is a true and correct copy of correspondence sent to Ragnar
`
`Olson from Scott D. Sanford of Amazon.com, dated August 13, 2019, which was designated
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`exhibit “Hayden 5” during the April 18, 2023 deposition of Scott Hayden and bears a stamp
`
`indicating the same. This exhibit contains highlighting that I added, pursuant to General Issue 11
`
`of the OGP.
`
`8.
`
`Attached as Exhibit 7 is a true and correct copy of correspondence sent to Scott D.
`
`Sanford from Ragnar Olson, dated September 26, 2019, which was designated exhibit “Hayden 7”
`
`during the April 18, 2023 deposition of Scott Hayden and bears a stamp indicating the same. This
`
`exhibit contains highlighting that I added, pursuant to General Issue 11 of the OGP.
`
`9.
`
`Attached as Exhibit 8 is a true and correct copy of the Second Notice of Patent
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`Infringement correspondence sent to CEO of Amazon.com Jeff Bezos from Ragnar Olson, dated
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`October 25, 2019, which was designated exhibit “Hayden 6” during the April 18, 2023 deposition
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`of Scott Hayden and bears a stamp indicating the same. This exhibit contains highlighting that I
`
`added, pursuant to General Issue 11 of the OGP.
`
`10.
`
`Attached as Exhibit 9 is a true and correct copy of Docket Number 91, in Global
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`eTicket Exch. Ltd. v. TicketMaster L.L.C., No. 6:21-cv-00399-ADA (W.D. Tex.), which is a
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`redacted copy of TicketMaster LLC’s Motion for Partial Summary Judgment of No Willful
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`Infringement.
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`11.
`
`Attached as Exhibit 10 is a true and correct copy of Docket Number 161, in Global
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`eTicket Exch. Ltd. v. TicketMaster L.L.C., No. 6:21-cv-00399-ADA (W.D. Tex.), which is an
`
`
`
`2
`
`
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`Case 6:21-cv-00898-ADA Document 159 Filed 09/07/23 Page 4 of 4
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`Order and Reports and Recommendations of the United States Magistrate Judge, dated March 15,
`
`2023.
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`12.
`
`Attached as Exhibit 11 is a true and correct copy of Docket Number 221, in Global
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`eTicket Exch. Ltd. v. TicketMaster L.L.C., No. 6:21-cv-00399-ADA (W.D. Tex.), which is an
`
`Order Adopting Magistrate Judge’s Report and Recommendation, dated April 30, 2023.
`
`
`
`
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed on September 7, 2023, at Los Angeles, California.
`
`/s/ James Tsuei
`James Tsuei
`
`
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`3
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