`
`
`JEAN-PAUL CIARDULLO, CA Bar No. 284170
` jciardullo@foley.com
`FOLEY & LARDNER LLP
`555 South Flower Street, Suite 3300
`Los Angeles, CA 90071
`Telephone: 213-972-4500
`Facsimile: 213-486-0065
`
`ELEY O. THOMPSON (pro hac vice)
` ethompson@foley.com
`FOLEY & LARDNER LLP
`321 N. Clark Street, Suite 2800
`Chicago, IL 60654-5313
`Telephone: 312-832-4359
`Facsimile: 312-83204700
`
`RUBEN J. RODRIGUES (pro hac vice)
`rrodrigues@foley.com
`LUCAS I. SILVA (pro hac vice)
`lsilva@foley.com
`JOHN W. CUSTER (pro hac vice)
`jcuster@foley.com
`FOLEY & LARDNER LLP
`111 Huntington Avenue, Suite 2500
`Boston, MA 02199-7610
`Telephone: (617) 342-4000
`Facsimile: (617) 342-4001
`
`Attorneys for Plaintiff
`Philips North America LLC
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`WESTERN DIVISION
`
` Case No. 2:19-cv-06301-AB-KS
`DECLARATION OF RUBEN J.
`RODRIGUES IN SUPPORT OF
`PHILIPS NORTH AMERICA LLC’s
`OPENING CLAIM CONSTRUCTION
`BRIEF
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`Philips North America LLC,
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`Plaintiff,
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`vs.
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`Garmin International, Inc.
`Garmin USA, Inc. and Garmin Ltd.,
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`Defendants.
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`Case 2:19-cv-06301-AB-KS Document 77-1 Filed 06/26/20 Page 2 of 2 Page ID #:1827
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`I, Ruben J. Rodrigues, declare as follows:
`I am an attorney at Foley & Lardner LLP, counsel to plaintiff Philips North
`1.
`America LLC (“Philips”) in this case.
`Attached as Exhibit 1 is a true and accurate copy of U.S. Patent No. 6,013,007.
`2.
`Attached as Exhibit 2 is a true and accurate copy of U.S. Patent No. 6,976,958.
`3.
`Attached as Exhibit 3 is a true and accurate copy of U.S. Patent No. 7,088,233.
`4.
`Attached as Exhibit 4 is a true and accurate copy of U.S. Patent No. 8,277,377.
`5.
`Attached as Exhibit 5 is a true and accurate copy of the expert disclosure of Dr.
`6.
`Thomas Martin, Ph.D date June 22, 2020.
`Attached as Exhibit 6 is a true and accurate copy of the Notice of Allowability
`7.
`dated June 11, 2004 from the prosecution history of U.S. Patent No. 7,088,233.
`Attached as Exhibit 7 is a true and accurate copy of the definitions of “govern”
`8.
`and “personal” from Merriam-Webster’s online dictionary as accessed on May 29th, 2020 and
`June 5th, 2020 , respectively.
`Attached as Exhibit 8 is a true and accurate copy of U.S. Patent No. 9,314,192.
`9.
`10. Attached as Exhibit 9 is a true and accurate copy of U.S. Patent No. 9,801,542.
`11. Attached as Exhibit 10 is a true and accurate copy of the Collins English
`Dictionary definition of “govern.”
`12. Attached as Exhibit 11 is a true and accurate copy of a response to an office action
`from the prosecution history of U.S. Patent No. 8,277,377 dated March 16, 2010.
`13. Attached as Exhibit 12 is a true and accurate copy of an office action from the
`prosecution history of U.S. Patent No. 8,277,377 dated August 10, 2010.
`14. Attached as Exhibit 13 is a true and accurate copy of a petition for inter partes
`review filed by Garmin against U.S. Patent No. 7,088,233.
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated: June 26, 2019
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`/s/ Ruben J. Rodrigues
` Ruben J. Rodrigues
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` DECLARATION
`CASE NO. 2:19-cv-06301-AB-KS
`
`
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