Case 1:20-cv-00034-ADA Document 50-1 Filed 04/10/20 Page 1 of 4
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`AUSTIN DIVISION
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`v.
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`ANCORA TECHNOLOGIES, INC.,
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`Plaintiff,
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`LG ELECTRONICS INC. and LG
`ELECTRONICS U.S.A., INC.,
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`Defendants.
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`ANCORA TECHNOLOGIES, INC.,
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`Plaintiff,
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`SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
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`v.
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`CIVIL ACTION NO. 1:20-CV-0034
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`JURY TRIAL DEMANDED
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`CIVIL ACTION NO. 1:20-CV-0034
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`JURY TRIAL DEMANDED
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`Defendants.
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`FIRST SUPPLEMENTAL DECLARATION OF STEVEN M. SEIGEL
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`Tables of Exhibits
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`1. Exhibits Attached to March 20, 2020 Declaration in Support of Opening Brief
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`Ex. Document Description
`1.
` U.S. Patent No. 6,411,941 B1 (Mullor, et al.), dated June 25, 2002
` Exhibits 2 to 6: Excerpts of File History of U.S. Patent App. No. 09/164,777 (’941 Patent)
` March 28, 2002 – Examiner Notice of Allowance, Amendments, and Interview Summary
` Feb. 5, 2002 – Amendments and Response to Jan. 15, 2002 Office Action
` Jan. 15, 2002 – Examiner Non-Final Rejection
` Dec. 6, 2001 – Amendments and Response to June 22, 2001 Office Action
` Nov. 9, 2001 – Examiner Interview Summary
` Declaration of Ian Jestice, Ancora Techs., Inc. v. LG Electronics et al. (W.D. Tex.) (March 19,
`2020)
` Declaration of Ian Jestice, Ancora Techs., Inc. v. Apple Inc. (N.D. Cal.) (April 30, 2002)
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`2.
`3.
`4.
`5.
`6.
`7.
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`8.
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`7260073v1/016322
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`Case 1:20-cv-00034-ADA Document 50-1 Filed 04/10/20 Page 2 of 4
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`9.
`10.
`11.
`12.
`13.
`14.
`15.
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`16.
`17.
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` Declaration of Ian Jestice, Ancora Techs., Inc. v. HTC et al. (W.D. Wa.) (Aug. 26, 2019)
` THE TELECOMMUNICATIONS HANDBOOK (1999)
` MICROSOFT PRESS COMPUTER USER’S DICTIONARY (1998)
` MICROSOFT COMPUTER DICTIONARY (4th Ed. 1999)
` ENCYCLOPEDIA OF COMPUTER SCIENCE (4th Ed. 2000)
` PC MAGAZINE
` Ancora’s Opening Markman Brief, Ancora Techs., Inc. v. Toshiba et al. (C.D. Cal) (Jan. 26,
`2009) (excerpts)
` U.S. Patent No. 8,572,597 to Herle et al., assigned to Samsung Electronics Co., Ltd.
` U.S. Patent No. 9,674,578 to Kim et al., assigned to LG Electronics Inc.
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`2. Exhibits Attached to First Supplemental Declaration in Support of Responsive Brief
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`19.
`20.
`21.
`22.
`23.
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`Ex. Document Description
`18.
` Excerpt of File History of ’941 Patent - Beeble Hardware Stamping Technology Overview
`(September 2001)
` Excerpt of File History ’941 Patent - Nov. 14 2001 Remarks Made in Amendment
` Zadok et al., PGMake: A Portable Distributed Make System (1994)
` Zadok et al., On Incremental File System Development (2006)
` Michael B. Jones, Interposition Agent Toolkit (1993)
` Excerpt of File History of ’941 Patent – Aug. 3, 2009 Decision Granting Reexamination
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`Declaration
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`I, Steven M. Seigel, hereby declare as follows:
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`1.
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`I am an attorney in the law firm of Susman Godfrey, LLP. I am counsel for Plaintiff
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`Ancora Technologies, Inc. (“Ancora”). I am admitted pro hac vice to practice before this Court, and
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`I have personal knowledge of the matters set forth herein. If called as a witness, I could and would
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`testify competently thereto.
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`2.
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`I submit this First Supplemental Declaration in support of Ancora’s Responsive
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`Construction Brief.
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`3.
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`For the exhibits described below, some exhibits have been highlighted or otherwise
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`marked for emphasis.
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`4.
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`Attached to this declaration as Exhibit 18 is a true and correct copy of Beeble
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`Hardware Stamping Technology Overview (September 2001), included as “non-patent literature” in
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`7260073v1/016322
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`2
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`Case 1:20-cv-00034-ADA Document 50-1 Filed 04/10/20 Page 3 of 4
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`the File History of U.S. Patent Application No. 09/164,777 which matured into the ’941 Patent (the “
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`’941 File History”).
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`5.
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` Attached to this declaration as Exhibit 19 is a true and correct copy of the
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`applicant’s Nov. 14, 2001 Remarks Made in Amendment during prosecution of the ’941 Patent.
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`6.
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`Attached to this declaration as Exhibit 20 is a true and correct copy of a publication
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`by Erez Zadok et al., entitled PGMake: A Portable Distributed Make System (1994).
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`7.
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`Attached to this declaration as Exhibit 21 is a true and correct copy of a publication
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`by Erez Zadok et al., entitled On Incremental File System Development (2006).
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`8.
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`Attached to this declaration as Exhibit 22 is a true and correct copy of a publication
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`by Michael B. Jones entitled Interposition Agent Toolkit (1993), which is referenced and cited in
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`Exhibit 21.
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`9.
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`Attached to this declaration as Exhibit 23 is a true and correct copy of the August 3,
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`2009 Decision Granting Ex Parte Reexamination of the ’941 Patent.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Signed this 10th day of April, 2020, at Seattle, WA.
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`By: /s/ Steven M. Seigel
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`Steven M. Seigel
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`7260073v1/016322
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`Case 1:20-cv-00034-ADA Document 50-1 Filed 04/10/20 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I hereby certify that all counsel of record, who are deemed to have consented to electronic
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`service are being served this 10th day of April, 2020, with a copy of this document via the Court’s
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`CM/ECF system.
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`/s/ Michelle Wimmer
`Michelle Wimmer
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`7260073v1/016322
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