throbber
Case 1:13-cv-00919-LPS Document 329 Filed 03/12/21 Page 1 of 7 PageID #: 34342
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 13-919-LPS
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`)))))))))
`
`ARENDI S.A.R.L.,
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`DECLARATION OF ROBERT UNIKEL IN SUPPORT OF GOOGLE LLC’S
`MOTION FOR SUMMARY JUDGMENT OF NONINFRINGEMENT
`
`David E. Moore (#3983)
`Bindu A. Palapura (#5370)
`Stephanie E. O’Byrne (#4446)
`POTTER ANDERSON & CORROON LLP
`Hercules Plaza, 6th Floor
`1313 N. Market Street
`Wilmington, DE 19801
`Tel: (302) 984-6000
`dmoore@potteranderson.com
`bpalapura@potteranderson.com
`sobyrne@potteranderson.com
`
`Attorneys for Defendant Google LLC
`
`OF COUNSEL:
`
`Robert W. Unikel
`Michelle Marek Figueiredo
`John Cotiguala
`Matt Lind
`PAUL HASTINGS LLP
`71 South Wacker Drive, Suite 4500
`Chicago, IL 60606
`Tel: (312) 449-6000
`
`Robert R. Laurenzi
`Chad J. Peterman
`PAUL HASTINGS LLP
`200 Park Avenue
`New York, NY 10166
`Tel: (212) 318-6000
`
`Ariell Bratton
`PAUL HASTINGS LLP
`4747 Executive Drive, 12th Floor
`San Diego, CA 92121
`Tel: (858) 458-3000
`
`PUBLIC VERSION
`
`

`

`Case 1:13-cv-00919-LPS Document 329 Filed 03/12/21 Page 2 of 7 PageID #: 34343
`
`Ginger Anders
`MUNGER, TOLLES & OLSON LLP
`601 Massachusetts Avenue NW
`Suite 500E
`Washington, D.C. 20001
`Tel: (202) 220-1100
`
`Dated: March 5, 2021
`7108167 / 40549
`
`2
`
`Public Version Dated: March 12, 2021
`
`

`

`Case 1:13-cv-00919-LPS Document 329 Filed 03/12/21 Page 3 of 7 PageID #: 34344
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 13-919-LPS
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`)))))))))
`
`ARENDI S.A.R.L.,
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`DECLARATION OF ROBERT UNIKEL IN SUPPORT OF GOOGLE LLC’S
`MOTION FOR SUMMARY JUDGMENT OF NONINFRINGEMENT
`
`I, Robert Unikel, declare as follows:
`
`1.
`
`I am an attorney at Paul Hastings LLP, counsel for Google LLC in this matter. I have
`
`personal knowledge of the matters stated in this declaration and would testify truthfully
`
`to them if called upon to do so.
`
`2. Attached as Exhibit 1 is a true and correct copy of excerpts from the Expert Report of
`
`Dr. Trevor Smedley (and Appendix) regarding Google’s purported infringement dated
`
`August 7, 2020; Appendix, p. 1-135; Ex. B.
`
`3. Attached as Exhibit 2 is a true and correct copy of excerpts from the Reply Expert
`
`Report of Dr. Trevor Smedley regarding Google’s purported infringement dated
`
`December 4, 2020.
`
`4. Attached as Exhibit 3 is a true and correct copy of excerpts from the transcript of the
`
`deposition of Dr. Trevor Smedley taken on January 19, 2021.
`
`5. Attached as Exhibit 4 is a true and correct copy of a document titled “Linkify” found at
`
`https://developer.android.com/reference/android/text/util/Linkify and produced as
`
`RINARD_GOOGLE_0000994-0001012.
`
`PUBLIC VERSION
`
`

`

`Case 1:13-cv-00919-LPS Document 329 Filed 03/12/21 Page 4 of 7 PageID #: 34345
`
`6. Attached as Exhibit 5 is
`
`
`
`7. Attached as Exhibit 6 is a true and correct copy of a document titled “Linkify your
`
`.
`
`Text!” produced as GOOG101890-91.
`
`8. Attached as Exhibit 7 is
`
`
`
`
`
`
`
`.
`
`9. Attached as Exhibit 8 is a true and correct copy of a document titled “WikiNotes for
`
`Android: Routing Intents” produced at GOOG00101900.
`
`10. Attached as Exhibit 9 is a true and correct copy of the Accelerated Examination Support
`
`Document submitted on July 22, 2010 during the prosecution of Patent No. 7,921,356,
`
`produced as AHL0164696-845.
`
`11. Attached as Exhibit 10 is a true and correct copy of U.S. Patent No. 6,323,853
`
`(“Hedloy”).
`
`12. Attached as Exhibit 11 is a true and correct copy of U.S. Patent No.5,946,647
`
`(“Goodwin”).
`
`13. Attached as Exhibit 12 is a true and correct copy of U.S. Patent No. 5,644,735
`
`(“Luciw”).
`
`14. Attached as Exhibit 13 is a true and correct copy of the Patent Owner’s Post-Institution
`
`Response in IPR2014-00452 brought against U.S. Patent No. 6,323,853, produced at
`
`ARENDI148474-536.
`
`15. Attached as Exhibit 14 is a true and correct copy of excerpts from the transcript of the
`
`deposition of Atle Hedloy, taken on October 29, 2019.
`
`16. Attached as Exhibit 15 is a true and correct copy of excerpts from the transcript of the
`
`2
`
`

`

`Case 1:13-cv-00919-LPS Document 329 Filed 03/12/21 Page 5 of 7 PageID #: 34346
`
`deposition of Atle Hedloy, taken on November 5, 2019.
`
`17. Attached as Exhibit 16 is a true and correct copy of excerpts from the transcript of the
`
`deposition of Atle Hedloy, taken on November 6, 2019.
`
`18. Attached as Exhibit 17 is a true and correct copy of
`
`https://developer.android.com/guide/platform, produced at
`
`RINARD_GOOGLE_0001242-46.
`
`19. Attached as Exhibit 18 is a true and correct copy of the Petition for Inter Partes review
`
`IPR2014-00208 for U.S. Patent No. 7,917,843, produced at FOX_0009000.
`
`20. Attached as Exhibit 19 is a true and correct copy of Exhibit 1006 from IPR petition
`
`IPR2014-00208, produced at FOX_0009655, and which includes a copy of “From
`
`Document to Objects, An Overview of LiveDoc” at FOX_0009659 and “Drop Zones, An
`
`Extension to LiveDoc” at FOX_0009665 (collectively “LiveDoc/DropZones”).
`
`21. Attached as Exhibit 20 is a true and correct copy of “Common Intents” from
`
`https://developer.android.com/guide/components/intents-common, produced at
`
`ARENDI_G329272.
`
`22. Attached as Exhibit 21 is a true and correct copy of “Newton Programmer’s Guide,”
`
`produced at ARENDI-DEFS00003649.
`
`23. Attached as Exhibit 22 is a true and correct copy of excerpts from the transcript of the
`
`deposition of Dr. Martin Rinard taken on December 17, 2021.
`
`24. Attached as Exhibit 23 is
`
`
`
`.
`
`
`
`25. Attached as Exhibit 24 is a true and correct copy of excerpts from the transcript of the
`
`deposition of Dr. Earl Sacerdoti taken on January 20, 2021.
`
`3
`
`

`

`Case 1:13-cv-00919-LPS Document 329 Filed 03/12/21 Page 6 of 7 PageID #: 34347
`
`26. Attached as Exhibit 25 is a copy of email correspondence between counsel for Arendi
`
`and Google, dated March 8, 2019, confirming that “Arendi is only accusing devices
`
`based on use of those applications that were preinstalled on the Google . . . devices at the
`
`time those devices were delivered to users.”
`
`27. Attached as Exhibit 26 is a
`
`
`
`.
`
`
`
`28. Attached as Exhibit 27 is a true and correct copy of U.S. Patent No. 5,859,636 to Pandit.
`
`29. Attached as Exhibit 28 is a true and correct copy of a Terminal Disclaimer filed during
`
`prosecution of the ’843 Patent, produced at AHL0134444.
`
`30. Attached as Exhibit 29 is a
`
`
`
`31. Attached as Exhibit 30 is
`
`32. Attached as Exhibit 31 is
`
`33. Attached as Exhibit 32 is
`
`.
`
`.
`
`.
`
`
`
`34. Exhibit 33 is a true and correct copy of a document titled “TextView,” produced at
`
`ARENDI_G330679.
`
`35. Exhibit 34 is
`
`.
`
`
`
`.
`
`
`
`
`
`36. Exhibit 35 is a true and correct copy of a document titled “Frequently Asked Questions,”
`
`produced at ARENDI_G329620-630.
`
`37. Exhibit 36 is a true and correct copy of a document titled “CyberDesk: a framework for
`
`4
`
`

`

`Case 1:13-cv-00919-LPS Document 329 Filed 03/12/21 Page 7 of 7 PageID #: 34348
`
`providing self-integrating context-aware services,” produced at AHL0121553.
`
`38. Exhibit 37 is a true and correct copy of a document titled “Apple Internet Address
`
`Detectors User’s Manual,” produced at ARENDI_DEFS00000591.
`
`39. Exhibit 38 is a true and correct copy of a document titled “The Selection Recognition
`
`Agent: Instant Access to Relevant Information and Operations,” produced at
`
`AHL0122361.
`
`I declare under penalty of perjury under the laws of the United States of America that the
`
`foregoing is true and correct and that this declaration was executed on March 5, 2021, at
`
`Chicago, Illinois.
`
`7108169
`
`/s/ Robert W. Unikel
`Robert W. Unikel
`
`5
`
`

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