throbber
Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 1 of 14 PageID #: 31058
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`ARENDI S.A.R.L.,
`
`Plaintiff,
`
`v.
`
`MOTOROLA MOBILITY LLC
`f/k/a MOTOROLA MOBILITY, INC.,
`
`Defendant.
`
`ARENDI S.A.R.L.,
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`C.A. No. 12-1601-LPS
`
`Original Version Filed: March 5, 2021
`Public Version Filed: March 10, 2021
`
`C.A. No. 13-919-LPS
`
`Original Version Filed: March 5, 2021
`Public Version Filed: March 10, 2021
`
`DECLARATION OF SETH ARD
`
`I, Seth Ard, hereby declare as follows.
`
`1.
`
`I am over 18 years of age, of sound mind, and otherwise competent to make this
`
`declaration. The evidence set out in the foregoing Declaration is based on my personal knowledge.
`
`2.
`
`I am an attorney and partner at the law firm Susman Godfrey LLP, counsel of record
`
`for Plaintiff, Arendi S.à.r.l. in the above-captioned action. I am admitted pro hac vice to practice
`
`before this Court.
`
`3.
`
`Attached as Exhibit 1 is a true and correct copy of Apple Inc. v. Arendi S.A.R.L.
`
`IPR2014-00208, Paper No. 1 (P.T.A.B. Dec. 2, 2013) (Petition for Inter Partes Review of ’843)
`
`produced by Defendants as FOX_0009000 - FOX_0009060.
`
`1
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 2 of 14 PageID #: 31059
`
`4.
`
`Attached as Exhibit 2 is a true and correct copy of Motorola Mobility LLC v. Arendi
`
`S.A.R.L. IPR2014-00203, Paper No. 3 (P.T.A.B. Dec. 2, 2013) (Petition for Inter Partes Review
`
`or ’993 Patent) produced by Defendants as FOX_0012183 – FOX_0012246.
`
`5.
`
`Attached as Exhibit 3 is a true and correct copy of Apple Inc. v. Arendi S.A.R.L.
`
`IPR2014-00206, Paper No. 3 (P.T.A.B. Dec. 2, 2013) (Petition for Inter Partes Review of ’854
`
`Patent) produced by Defendants as FOX_0009888 – FOX_0009951.
`
`6.
`
`Attached as Exhibit 4 is a true and correct copy of Apple Inc. v. Arendi S.A.R.L.
`
`IPR2014-00207, Paper No. 3 (P.T.A.B. Dec. 2, 2013) (Petition for Inter Partes Review of ’854
`
`Patent) produced by Arendi as ARENDI 199613 – ARENDI 199675.
`
`7.
`
`Attached as Exhibit 5 is a true and correct copy of Google Inc. v. Arendi S.A.R.L.
`
`IPR2014-00450, Paper No. 1 (P.T.A.B. Feb. 20, 2014) (Petition for Inter Partes Review of ’356
`
`Patent) produced by Arendi as FOX_0008130 – FOX_0008194.
`
`8.
`
`Attached as Exhibit 6 is a true and correct copy of Google Inc. v. Arendi S.A.R.L.
`
`IPR2014-00452, Paper No. 1 (P.T.A.B. Feb. 21, 2014) (Petition for Inter Partes Review of ’853
`
`Patent) produced by Arendi as ARENDI 148048 – ARENDI 148110.
`
`9.
`
`Attached as Exhibit 7 is a true and correct copy of Apple Inc. v. Arendi S.A.R.L.
`
`IPR2014-00208, Paper No. 8 (P.T.A.B. June 9, 2015) (Decision to Institute for ’843 Patent)
`
`produced by produced by Arendi as ARENDI 210101 – ARENDI 210120.
`
`10.
`
`Attached as Exhibit 8 is a true and correct copy of Apple Inc. v. Arendi S.A.R.L.
`
`IPR2014-00208, Paper No. 33 (P.T.A.B. June 9, 2015) (Final Written Decision for ’843 Patent)
`
`produced by Arendi as ARENDI 209923 – ARENDI 209938.
`
`
`
`2
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 3 of 14 PageID #: 31060
`
`11.
`
`Attached as Exhibit 9 is a true and correct copy of the Expert Report of Edward
`
`Fox, Ph.D. on the Invalidity of U.S. Patent No. 7,917,843 served by Google LLC and Motorola
`
`Mobility LLC (collectively, “Defendants”) on August 7, 2020.
`
`12.
`
`Attached as Exhibit 10 is a true and correct copy of the Reply Expert Report of
`
`Edward Fox, Ph.D. on the Invalidity of U.S. Patent No. 7,917,843 served by Defendants on
`
`December 4, 2020.
`
`13.
`
`Attached as Exhibit 11 is a true and correct copy of U.S. Patent No. 7,917,843,
`
`produced by Arendi in this litigation as AHL0118048 - AHL0118078.
`
`14.
`
`Lodged with the Court as Exhibit 12 is a true and correct copy of ARENDI100002,
`
`which is a copy of a CD-ROM containing part 1 of 2 of the file wrapper for the ’843 Patent. The
`
`copied CD-ROM was obtained by Arendi from the United States Patent and Trademark Office.
`
`Arendi produced ARENDI100002 to Defendants on August 27, 2013.
`
`15.
`
`Attached as Exhibit 13 is a true and correct copy of the sealed certificate from the
`
`United States Patent and Trademark Office in conjunction with Exhibit 12 and certifying the
`
`original of Exhibit 12 as a true copy and produced by Arendi to Defendants as ARENDI100001
`
`on August 27, 2013.
`
`16.
`
`Attached as Exhibit 14 is a true and correct copy of the document titled
`
`“CyberDesk: A Framework for Providing Self-Integrating Ubiquitous Software Services” with the
`
`citation GVU Technical Report, GIT-GVU-97-10, produced by Arendi to Defendants as
`
`AHL0122266 – AHL0122283 on October 18, 2013.
`
`17.
`
`Attached as Exhibit 15 is a true and correct copy of the document titled
`
`“CyberDesk: Automated Integration of Desktop and Network Services” with the citation CHI ’97
`
`Note, produced by Arendi to Defendants as AHL0122288 – AHL0122292 on October 18, 2013.
`
`
`
`3
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 4 of 14 PageID #: 31061
`
`18.
`
`Attached as Exhibit 16 is a true and correct copy of the document titled “Context-
`
`awareness in wearable and ubiquitous computing” with the citation GVU Technical Report GIT-
`
`GVU-97-11, produced by Arendi to Defendants as AHL0145938– AHL0145950 on October 18,
`
`2013.
`
`19.
`
`Attached as Exhibit 17 is a true and correct copy of the document titled
`
`“CyberDesk: a framework for providing self-integrating context-aware services” with the citation
`
`Knowledge-Based Systems 11 (1998) 3 - 13, produced by Arendi to Defendants as AHL0121553
`
`– AHL0121563 on October 18, 2013.
`
`20.
`
`Attached as Exhibit 18 is a true and correct copy of the document titled “Applying
`
`Dynamic Integration as a Software Infrastructure for Context-Aware Computing” produced by
`
`Arendi to Defendants as AHL0122306 – AHL0122315 on October 18, 2013.
`
`21.
`
`Attached as Exhibit 19 is a true and correct copy of the document titled “Context-
`
`Aware Computing: The CyberDesk Project” produced by Defendants in this litigation as
`
`ARENDI-DEFS00021056 - ARENDI-DEFS00021058.
`
`22.
`
`Attached as Exhibit 20 is a true and correct copy of the document titled “Future
`
`Computing Environments: CyberDesk,” produced by Defendants in this litigation as ARENDI-
`
`DEFS00021090 - ARENDI-DEFS00021091.
`
`23.
`
`Attached as Exhibit 21 is a true and correct copy of the document titled
`
`“CyberDesk: A Framework for Providing Self-Integrating Context-Aware Services” produced by
`
`Defendants in this litigation as FOX_006473 - FOX_006488.
`
`24.
`
`Attached as Exhibit 22 is a true and correct copy of the document titled
`
`“CyberDesk: A Framework for Providing Self-Integrating Ubiquitous Software Services”
`
`
`
`4
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 5 of 14 PageID #: 31062
`
`produced by Defendants
`
`in this
`
`litigation as ARENDI- DEFS00001151 - ARENDI-
`
`DEFS00001160.
`
`25.
`
`Attached as Exhibit 23 is a true and correct copy of the Joint Initial Invalidity
`
`Contentions of Defendants LG Electronics Inc.., LG Electronics USA, Inc. and LG Electronics
`
`Mobilecomm U.S.A., Inc.; Blackberry Limited and Blackberry Corporation; Nokia Corporation
`
`and Nokia Inc.; HTC Corp. a/k/a High Tech Computer Corp, HTC America, Inc., and Exedea,
`
`Inc.; Motorola Mobility LLC, f/k/a Motorola Mobility Inc.; Sony Mobile Communications (USA)
`
`Inc. f/k/a Sony Ericsson Mobile Communications (UYSA) Inc., Sony Corporation, and Sony
`
`Corporation of America; Google Inc.; and Yahoo! Inc. (“Initial Invalidity Contentions”) served by
`
`Defendants in this litigation on January 17, 2014.
`
`26.
`
`Attached as Exhibit 24 is a true and correct copy of Exhibit B-10 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`27.
`
`Attached as Exhibit 25 is a true and correct copy of Exhibit B-14 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`28.
`
`Attached as Exhibit 26 is a true and correct copy of Exhibit C-7 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`29.
`
`Attached as Exhibit 27 is a true and correct copy of Exhibit C-8 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`30.
`
`Attached as Exhibit 28 is a true and correct copy of Exhibit C-10 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`31.
`
`Attached as Exhibit 29 is a true and correct copy of Exhibit C-11 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`
`
`5
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 6 of 14 PageID #: 31063
`
`32.
`
`Attached as Exhibit 30 is a true and correct copy of Exhibit C-31 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`33.
`
`Attached as Exhibit 31 is a true and correct copy of Exhibit C-32 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`34.
`
`Attached as Exhibit 32 is a true and correct copy of Exhibit C-33 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`35.
`
`Attached as Exhibit 33 is a true and correct copy of Exhibit C-42 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`36.
`
`Attached as Exhibit 34 is a true and correct copy of Exhibit C-53 to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`37.
`
`Attached as Exhibit 35 is a true and correct copy of Exhibit G to the Joint Initial
`
`Invalidity Contentions served by Defendants in this litigation on January 17, 2014.
`
`38.
`
`Attached as Exhibit 36 is a true and correct copy of pages 1-3, 16-17, 28, 30-33, 82
`
`and 272 of the transcript of the Deposition of Anind Dey, dated November 12, 2019.
`
`39.
`
`Attached as Exhibit 37 is a true and correct copy of the Joint Amended Invalidity
`
`Contentions of Defendants LG Electronics Inc., LG Electronics USA, Inc. and LG Electronics
`
`Mobilecomm U.S.A., Inc.; Blackberry Limited And Blackberry Corporation; Microsoft Mobile,
`
`Inc. (f/k/a Nokia Inc.); Motorola Mobility LLC, f/k/a Motorola Mobility Inc.; Sony Mobile
`
`Communications (USA) Inc. f/k/a Sony Ericsson Mobile Communications (USA) Inc., Sony
`
`Corporation, and Sony Corporation of America; Google LLC; Oath Holdings Inc.; Apple Inc.; and
`
`Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (“Joint Amended Invalidity
`
`Contentions”) served by Defendants in this litigation on March 27, 2019.
`
`
`
`6
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 7 of 14 PageID #: 31064
`
`40.
`
`Attached as Exhibit 38 is a true and correct copy of Exhibit C-7A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`41.
`
`Attached as Exhibit 39 is a true and correct copy of Exhibit C-11A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`42.
`
`Attached as Exhibit 40 is a true and correct copy of Exhibit C-22A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`43.
`
`Attached as Exhibit 41 is a true and correct copy of Exhibit C-27A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`44.
`
`Attached as Exhibit 42 is a true and correct copy of Exhibit C-26A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`45.
`
`Attached as Exhibit 43 is a true and correct copy of Exhibit C-29A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`46.
`
`Attached as Exhibit 44 is a true and correct copy of Exhibit C-33A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`47.
`
`Attached as Exhibit 45 is a true and correct copy of Exhibit C-36A to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`48.
`
`Attached as Exhibit 46 is a true and correct copy of Exhibit C-73 to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`49.
`
`Attached as Exhibit 47 is a true and correct copy of Exhibit E-57 to the Joint
`
`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
`
`50.
`
`Attached as Exhibit 48 is a true and correct copy of Google LLC’s Subpoena to
`
`Anind Dey, dated and served on Arendi on September 13, 2019.
`
`
`
`7
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 8 of 14 PageID #: 31065
`
`51.
`
`Attached as Exhibit 49 is a true and correct copy of Motorola Mobility LLC’s
`
`Subpoena to Anind Dey, dated and served on Arendi on September 13, 2019.
`
`52.
`
`Attached as Exhibit 50 is a true and correct copy of Google LLC’s Subpoena to
`
`Georgia Institute of Technology, dated and served on Arendi on August 13, 2019.
`
`53.
`
`Attached as Exhibit 51 is a true and correct copy of Motorola Mobility LLC’s
`
`Subpoena to Georgia Institute of Technology, dated and served on Arendi on August 13, 2019.
`
`54.
`
`Attached as Exhibit 52 is a true and correct copy of the document titled “Applying
`
`Dynamic Integration as a Software Infrastructure for Context-Aware Computing” produced by
`
`Defendants in this litigation as ARENDI- DEFS00021045 - ARENDI- DEFS00021050.
`
`55.
`
`Attached as Exhibit 53 are true and correct copies of the documents titled “From
`
`Documents to Objects: An Overview of LiveDoc” and “Drop Zones: An Extension of LiveDoc”
`
`produced by Defendants
`
`in
`
`this
`
`litigation as ARENDI-DEFS00003076 – ARENDI-
`
`DEFS00003095.
`
`56.
`
`Attached as Exhibit 54 is a true and correct copy of the document titled
`
`“Collaborative Programmable Intelligent Agents” (Nardi) produced by Defendants in this
`
`litigation as ARENDI-DEFS00003329 – ARENDI-DEFS00003337.
`
`57.
`
`Attached as Exhibit 55 is a true and correct copy of the document titled “Drop
`
`Zones: An Extension to LiveDoc” produced by Defendants in this litigation as ARENDI-
`
`DEFS00000642 – ARENDI-DEFS00000646.
`
`58.
`
`Attached as Exhibit 56 is a true and correct copy of the document titled “Apple
`
`Data Detectors User’s Manual” produced by Arendi to Defendants as AHL0120682 –
`
`AHL0120697 on October 18, 2013.
`
`
`
`8
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 9 of 14 PageID #: 31066
`
`59.
`
`Attached as Exhibit 57 is a true and correct copy of the document titled “Apple
`
`Internet Address Detectors User’s Manual” produced by Arendi to Defendants as AHL0123031 –
`
`AHL0123046 on October 18, 2013.
`
`60.
`
`Attached as Exhibit 58 is a true and correct copy of the document titled
`
`“Developer’s Guide to Apple Data Detectors” produced by Arendi to Defendants as AHL0124440
`
`– AHL0124473 on October 18, 2013.
`
`61.
`
`Attached as Exhibit 59 is a true and correct copy of the document referenced as
`
`Apple Data Detectors Webpages and produced by Arendi to Defendants as AHL0135930 –
`
`AHL0135944 on October 18, 2013.
`
`62.
`
`Attached as Exhibit 60 is a true and correct copy of the document titled “Claris
`
`Em@iler Getting Started” produced by Arendi to Defendants as AHL0140270 – AHL0140334 on
`
`October 18, 2013.
`
`63.
`
`Attached as Exhibit 61 is a true and correct copy of the document titled “Apple
`
`Introduces Internet Address Detectors” produced by Arendi to Defendants as AHL0114770 –
`
`AHL0114773 on October 18, 2013.
`
`64.
`
`Attached as Exhibit 62 is a true and correct copy of the document titled
`
`“MessagePad 2000 User’s Manual” produced by Defendants in this litigation as ARENDI-
`
`DEFS00004995 – ARENDI-DEFS00005285.
`
`65.
`
`Attached as Exhibit 63 is a true and correct copy of the document titled “Newton
`
`2.0 User Interface Guidelines” produced by Defendants in this litigation as ARENDI-
`
`DEFS00003338 – ARENDI-DEFS00003644.
`
`
`
`9
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 10 of 14 PageID #: 31067
`
`66.
`
`Attached as Exhibit 64 is a true and correct copy of the document titled “Newton
`
`Programmer’s Guide” produced by Defendants in this litigation as ARENDI-DEFS00003649 –
`
`ARENDI-DEFS00004590.
`
`67.
`
`Attached as Exhibit 65 is a true and correct copy of the document tilted “Review:
`
`Eudora Pro 3.0” produced by Defendants in this litigation as ARENDI-DEFS00014105 -
`
`ARENDI-DEFS00014111.
`
`68.
`
`Attached as Exhibit 66 is a true and correct copy of the document tilted “Eudora
`
`Mail Pro: Version 3.0 for Windows User Manual” produced by Arendi in this litigation as
`
`ARENDI315568 – ARENDI 315722.
`
`69.
`
`Attached as Exhibit 67 is a true and correct copy of the document tilted “Eudora
`
`Mail Pro: Version 3.1 for Macintosh User Manual” produced by Arendi in this litigation as
`
`AHL0154945 – AHL0155143 on October 18, 2013.
`
`70.
`
`Attached as Exhibit 68 is a true and correct copy of the document tilted “Special
`
`Edition Using Microsoft Word 97,” ch. 17 “Mastering Envelopes, Mail Merge, and Form Letters”
`
`produced by Arendi in this litigation as AHL0194629 – AHL0194667.
`
`71.
`
`Attached as Exhibit 69 is a true and correct copy of the document titled “Getting
`
`Results with Microsoft Office 97,” produced by Apple in this litigation as ARENDI-
`
`DEFS00001442 - ARENDI-DEFS00002143.
`
`72.
`
`Attached as Exhibit 70 is a true and correct copy of the document titled “Using
`
`Microsoft Outlook 97, Special Edition” produced by Arendi in this litigation as ARENDI 203925
`
`– ARENDI 204221.
`
`
`
`10
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 11 of 14 PageID #: 31068
`
`73.
`
`Attached as Exhibit 71 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 6,085,201, produced by Arendi in this litigation as
`
`AHL0125164 - AHL0125173 on October 18, 2013.
`
`74.
`
`Attached as Exhibit 72 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 6,377,965, produced by Arendi in this litigation as
`
`AHL0120123 - AHL0120140 on October 18, 2013.
`
`75.
`
`Attached as Exhibit 73 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,392,386, produced by Arendi in this litigation as
`
`ARENDI 7985 – ARENDI 8001 on October 18, 2013.
`
`76.
`
`Attached as Exhibit 74 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,392,386, produced by Arendi in this litigation as
`
`ARENDI 11243 - ARENDI 11259 on October 18, 2013.
`
`77.
`
`Attached as Exhibit 75 is a true and correct copy of the document tilted “The
`
`Selection Recognition Agent: Instant Access to Relevant Information and Operations” produced
`
`by Defendants in this litigation as ARENDI-DEFS00008664 - ARENDI-DEFS00008669.
`
`78.
`
`Attached as Exhibit 76 is a true and correct copy of the document titled “The
`
`Selection Recognition Agent: Instant Access to Relevant Information and Operations” produced
`
`by Arendi to Defendants as AHL0122361– AHL0122366 on October 18, 2013.
`
`79.
`
`Attached as Exhibit 77 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,477,447 produced by Defendants in this litigation as
`
`ARENDI-DEFS00009411 - ARENDI-DEFS00009440.
`
`
`
`11
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 12 of 14 PageID #: 31069
`
`80.
`
`Attached as Exhibit 78 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,644,735 produced by Defendants in this litigation as
`
`FOX_0012496 - FOX_0012524.
`
`81.
`
`Lodged with the Court as Exhibit 79 is a true and correct copy of ARENDI-
`
`DEFS00000001, which contains the video files ADD-2xcdrom.avi, ADD-720x480.mov, ADD-
`
`DSLmedium.mov, and Data Detectors @ MW ’96.mov.
`
`82.
`
`Lodged with the Court as Exhibit 80 is a true and correct copy of ARENDI-
`
`DEFS00021315, produced by Defendants in this litigation.
`
`83.
`
`Attached as Exhibit 81 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,946,647, produced by Defendants in this litigation as
`
`ARENDI-DEFS00010281 - ARENDI-DEFS00010296.
`
`84.
`
`Attached as Exhibit 82 is a true and correct copy of the transcript of the Deposition
`
`of Jim Miller in the above-captioned cases, dated October 16, 2016.
`
`85.
`
`Attached as Exhibit 83 is a true and correct copy of the document titled “United
`
`States Patent” and bearing the Patent No. 5,859,636, produced by Defendants in this litigation as
`
`ARENDI-DEFS00010090 - ARENDI-DEFS00010105.
`
`86.
`
`Exhibit 84 is intentionally blank.
`
`87.
`
`Attached as Exhibit 85 is a true and correct copy of the document titled “Apple
`
`Introduces Internet Address Detectors” produced by Defendants in this litigation as ARENDI-
`
`DEFS00000623 - ARENDI-DEFS00000627.
`
`88.
`
`Attached as Exhibit 86 is a true and correct copy of the document titled “US
`
`Geographic Detectors Read Me.txt,” produced by Defendants in this litigation as ARENDI-
`
`DEFS00011455 - ARENDI-DEFS00011456.
`
`
`
`12
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 13 of 14 PageID #: 31070
`
`89.
`
`Attached as Exhibit 87 is a true and correct copy of Nardi et al, “Collaborative
`
`Programmable Intelligent Agents,” produced by Arendi in this litigation as AHL0125017 –
`
`AHL0125025 on October 18, 2013.
`
`90.
`
`Attached as Exhibit 88 is a true and correct copy of the deposition transcript of Atle
`
`Hedløy in this litigation, dated October 29, 2019.
`
`91.
`
`Attached as Exhibit 89 is a true and correct copy of the deposition transcript of Atle
`
`Hedløy in this litigation, dated October 30, 2019.
`
`92.
`
`Attached as Exhibit 90 is a true and correct copy of the deposition transcript of Atle
`
`Hedløy in this litigation, dated November 5, 2019.
`
`93.
`
`Attached as Exhibit 91 is a true and correct copy of the deposition transcript of Atle
`
`Hedløy in this litigation, dated November 6, 2019.
`
`
`
`94.
`
`Attached as Exhibit 92 is a true and correct copy of the deposition transcript of Atle
`
`Hedløy in this litigation, dated November 7, 2019.
`
`95.
`
`Attached as Exhibit 93 is a true and correct copy of the production email sent by
`
`Arendi to Defendants on August 27, 2013 with ARENDI 100001 - ARENDI 100007 and ARENDI
`
`100015 - ARENDI 100018.
`
`96.
`
`Attached as Exhibit 94 is a true and correct copy of the production email sent by
`
`Arendi to Defendants on October 18, 2013 with AHL 000001 – AHL 197687, ARENDI 000001 –
`
`ARENDI 17167, and ARENDI 100019 – ARENDI 100024.
`
`97.
`
`Attached as Exhibit 95 is a true and correct copy of the document titled “List of
`
`Patents and Publications for Applicant’s Corrected and Supplemental Information Disclosure
`
`Statement,” produced by Arendi in this litigation as AHL0165305 - AHL0165327 on October 18,
`
`2013.
`
`
`
`13
`
`

`

`Case 1:13-cv-00919-LPS Document 313 Filed 03/10/21 Page 14 of 14 PageID #: 31071
`
`98.
`
`Attached as Exhibit 96 is a true and correct copy of pages 1, 88, 118, and 248 of
`
`the deposition transcript of Frank Casanova, dated September 25, 2019.
`
`99.
`
`Attached as Exhibit 97 is a true and correct PDF copy of the “Assignments” page
`
`of the Public Patent Application Information Retrieval (“Public PAIR”) webpage of the United
`
`States Patent and Trademark Office for U.S. Patent No. 5,784,001, accessed March 5, 2021.
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is
`
`true and correct and that this declaration was executed on March 5, 2021.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/s/______________________
`Seth Ard
`
`14
`
`

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

Still Working On It

This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.

Give it another minute or two to complete, and then try the refresh button.

throbber

A few More Minutes ... Still Working

It can take up to 5 minutes for us to download a document if the court servers are running slowly.

Thank you for your continued patience.

This document could not be displayed.

We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.

Your account does not support viewing this document.

You need a Paid Account to view this document. Click here to change your account type.

Your account does not support viewing this document.

Set your membership status to view this document.

With a Docket Alarm membership, you'll get a whole lot more, including:

  • Up-to-date information for this case.
  • Email alerts whenever there is an update.
  • Full text search for other cases.
  • Get email alerts whenever a new case matches your search.

Become a Member

One Moment Please

The filing “” is large (MB) and is being downloaded.

Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.

Your document is on its way!

If you do not receive the document in five minutes, contact support at support@docketalarm.com.

Sealed Document

We are unable to display this document, it may be under a court ordered seal.

If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.


Access Government Site

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket