`
`
`
`IN THE UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`ALMONDNET, INC.,
`
`
`Plaintiff,
`
`
`
`Civil Action No. 6:21-cv-00898-ADA-DTG
`
`
`JURY TRIAL DEMANDED
`
`
`
`
`AMAZON.COM, INC.; AMAZON.COM
`SERVICES LLC; and AMAZON WEB
`SERVICES, INC.,
`
`
`v.
`
`Defendants.
`
`
`
`
`
`
`
`
`
`DECLARATION OF CHRISTOPHER L. LARSON IN SUPPORT
`OF AMAZON’S OPPOSITION TO ALMONDNET, INC.’S
`MOTIONS IN LIMINE
`
`I, Christopher L. Larson, hereby declare as follows:
`
`1.
`
`I am an attorney admitted in the States of California and Colorado and admitted to
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`this Court. I am a counsel with the law firm of Fenwick & West LLP, counsel of record for
`
`defendants Amazon.com, Inc., Amazon.com Services LLC, and Amazon Web Services, Inc.
`
`(collectively “Amazon”). I submit this declaration in support of Amazon’s Opposition to
`
`AlmondNet’s Motions in Limine.
`
`2.
`
`Attached hereto as Exhibit 1 is a true and correct copy of an excerpt of the Oral
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`Order on Motions in Limine, Astellas Pharma Inc. et al v. Sandoz Ince., et al, 1:20-cv-01589-JFB-
`
`CJB, Dkt. 501 (Jan. 27, 2023). This exhibit contains added highlighting, pursuant to General Issue
`
`11 of the Court’s Standing Order Governing Proceedings (OGP) 4.3—Patent Cases (“OGP”).
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`
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`Case 6:21-cv-00898-ADA Document 211 Filed 09/22/23 Page 2 of 4
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`
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`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of the Supplemental Expert
`
`Report of Dr. Eric Koskinen Regarding Infringement. This exhibit contains added highlighting,
`
`pursuant to General Issue 11 of the OGP.
`
`4.
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`Attached hereto as Exhibit 3 are true and correct copies of excerpts from the
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`Deposition Transcript of Henry Houh, PhD, dated August 15, 2023. This exhibit contains added
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`highlighting, pursuant to General Issue 11 of the OGP.
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`5.
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`Attached hereto as Exhibit 4 are true and correct copies of excerpts from the
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`Deposition Transcript of Henry Houh, PhD, dated August 30, 2023. This exhibit contains added
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`highlighting, pursuant to General Issue 11 of the OGP.
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`6.
`
`Attached hereto as Exhibit 5 are true and correct copies of excerpts from the
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`Deposition Transcript of Scott Hayden, dated April 18, 2023. This exhibit contains added
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`highlighting, pursuant to General Issue 11 of the OGP.
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`7.
`
`Attached hereto as Exhibit 6 is a true and correct copy of the Omnibus
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`Supplemental Objections and Responses of Defendants Amazon.com, Inc., Amazon.com Services
`
`LLC and Amazon Web Services, Inc. to Plaintiff AlmondNet, Inc.’s Interrogatories (Nos. 1-27).
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`This exhibit contains added highlighting, pursuant to General Issue 11 of the OGP.
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`8.
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`Attached hereto as Exhibit 7 is a true and correct copy of the Third Supplemental
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`Initial Disclosures of Defendants Amazon.com, Inc., Amazon.com Services LLC, and Amazon
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`Web Services, Inc., dated May 31, 2023. This exhibit contains added highlighting, pursuant to
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`General Issue 11 of the OGP.
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`9.
`
`Attached hereto as Exhibit 8 is a true and correct copy of SEC Form 10-K for
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`DoubleClick Inc., for the fiscal year ended December 31, 2004. This exhibit contains added
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`highlighting, pursuant to General Issue 11 of the OGP.
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`2
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`
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`Case 6:21-cv-00898-ADA Document 211 Filed 09/22/23 Page 3 of 4
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`
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`10.
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`Attached hereto as Exhibit 9 is a true and correct copy of SEC Form 10-Q for
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`DoubleClick Inc., for the quarterly period ended March 31, 2005. This exhibit contains added
`
`highlighting, pursuant to General Issue 11 of the OGP.
`
`11.
`
`Attached hereto as Exhibit 10 is a true and correct copy of SEC Form 10-K/A for
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`DoubleClick Inc., for the year ended December 31, 1998. This exhibit contains added
`
`highlighting, pursuant to General Issue 11 of the OGP.
`
`12.
`
`Attached hereto as Exhibit 11 is a true and correct copy of SEC Form 10-K for
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`DoubleClick Inc., for the fiscal year ended December 31, 1999. This exhibit contains added
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`highlighting, pursuant to General Issue 11 of the OGP.
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` declare under penalty of perjury under the laws of the United States of America that the
`
` I
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`foregoing is true and correct. Executed in San Francisco on September 22, 2023.
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`
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`
`
`/s/ Christopher L. Larson
`Christopher L. Larson
`
`
`
`3
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`
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`Case 6:21-cv-00898-ADA Document 211 Filed 09/22/23 Page 4 of 4
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`
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record who are deemed to have consented to electronic
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`service are being served with a true and correct copy of this document on September 22, 2023, via
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`the Court’s CM/ECF system per Local Rule CV 5(a)(3).
`
`/s/ Christopher L. Larson
`Christopher L. Larson
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`4
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