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`UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`C.A. No. 12-1601-LPS
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`PUBLIC VERSION
`MARCH 11, 2021
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`C.A. No. 13-919-LPS
`PUBLIC VERSION
`MARCH 11, 2021
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`ARENDI S.A.R.L.,
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`Plaintiff,
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`v.
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`MOTOROLA MOBILITY LLC
`f/k/a MOTOROLA MOBILITY, INC.,
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`Defendant.
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`ARENDI S.A.R.L.,
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`Plaintiff,
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`v.
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`GOOGLE LLC,
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`Defendant.
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`DECLARATION OF SETH ARD
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`I, Seth Ard, hereby declare as follows:
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`1.
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`I am over 18 years of age, of sound mind, and otherwise competent to make this
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`declaration. The evidence set out in the foregoing Declaration is based on my personal knowledge.
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`2.
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`I am an attorney and partner at the law firm Susman Godfrey LLP, and I am counsel
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`of record for Plaintiff, Arendi S.à.r.l., in the above-captioned action. I am admitted pro hac vice to
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`practice before this Court.
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`3.
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`Attached as Exhibit 1 is a true and correct copy of the Expert Report of Edward
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`Fox, Ph.D. on the Invalidity of U.S. Patent No. 7,917,843 served by Google LLC and Motorola
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`Mobility LLC (collectively, “Defendants”) on August 7, 2020.
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`1
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`Case 1:13-cv-00919-LPS Document 321 Filed 03/11/21 Page 2 of 2 PageID #: 33796
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`4.
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`Attached as Exhibit 2 is a true and correct copy of the Reply Expert Report of
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`Edward Fox, Ph.D. on the Invalidity of U.S. Patent No. 7,917,843 served by Defendants on
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`December 4, 2020.
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`5.
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`Attached as Exhibit 3 is a true and correct copy of Exhibit C-11A to the Joint
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`Amended Invalidity Contentions of Defendants LG Electronics Inc., LG Electronics USA, Inc.
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`and LG Electronics Mobilecomm U.S.A., Inc.; Blackberry Limited And Blackberry Corporation;
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`Microsoft Mobile, Inc. (f/k/a Nokia Inc.); Motorola Mobility LLC, f/k/a Motorola Mobility Inc.;
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`Sony Mobile Communications (USA) Inc. f/k/a Sony Ericsson Mobile Communications (USA)
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`Inc., Sony Corporation, and Sony Corporation of America; Google LLC; Oath Holdings Inc.;
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`Apple Inc.; and Samsung Electronics Co., Ltd. and Samsung Electronics America, Inc. (“Joint
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`Amended Invalidity Contentions”) served by Defendants in this litigation on March 27, 2019.
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`6.
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`Attached as Exhibit 4 is a true and correct copy of Exhibit C-45A to the Joint
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`Amended Invalidity Contentions served by Defendants in this litigation on March 27, 2019.
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`7.
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`Attached as Exhibit 5 is a true and correct copy of the transcript of the Deposition
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`of Dr. Edward Fox in the above-captioned cases, dated January 15, 2021.
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`8.
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`Attached as Exhibit 6 is a true and correct copy of U.S. Patent No. 7,917,843,
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`produced by Arendi in this litigation as AHL0118048-0118078.
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`I declare under penalty of perjury under the laws of the United States that the foregoing is
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`true and correct and that this declaration was Executed on March 4, 2021.
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`/s/_________________________
`Seth Ard
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`2
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