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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`Case No. 6:21-cv-01101-ADA
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`JURY TRIAL DEMANDED
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`DECLARATION OF DREW HOLLANDER IN SUPPORT OF AIRE TECHNOLOGY
`LTD’S OPPOSITION TO APPLE INC.’S MOTION TO MODIFY STAY ORDER
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`AIRE TECHNOLOGY LTD.,
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`APPLE INC.,
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`v.
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`Plaintiff,
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`Defendant.
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`Case 6:21-cv-01101-ADA Document 74-1 Filed 01/26/23 Page 2 of 2
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`I, Drew B. Hollander, hereby declare under the penalty of perjury as follows:
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`1.
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`I am an attorney at BC Law Group, P.C., counsel of record for Aire Technology
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`Ltd. (“Aire”). I am one of the attorneys responsible for representing Aire in this matter. I have
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`personal knowledge of all facts stated in this declaration and if called as a witness, could and would
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`competently testify to these facts. I respectfully submit this declaration in support of Aire’s
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`opposition to Apple’s motion to modify stay order.
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`2.
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`The parties have already exchanged and responses to substantive (i.e., non-venue)
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`requests for productions and interrogatories. As of the commencement of this action, Apple has
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`produced over 500,000 pages of documents. Additionally, Aire’s source code experts made six
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`trips to review Apple’s source code, as well as a seventh trip to review third-party source code.
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`3.
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`Apple served its preliminary invalidity contentions on March 31, 2022. Apple
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`identified over 10 alleged prior art systems as potentially invalidating prior art. Additionally,
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`Apple has advanced § 112 invalidity arguments as to all Asserted Patents.
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`Executed on this 26th day of January 2023 in Ardsley, NY.
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`/s/ Drew B. Hollander
`Drew B. Hollander
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`1
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