`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`
`ANCORA TECHNOLOGIES, INC.,
`
`
`Civil Action No. 6:21-cv-00735-ADA
`
`JURY TRIAL DEMANDED
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`v.
`
`GOOGLE, LLC,
`
`Plaintiff,
`
`Defendant.
`
`
`DECLARATION OF STEVEN SEIGEL IN SUPPORT OF ANCORA TECHNOLOGIES,
`INC.’S OPPOSITION TO GOOGLE LLC’S MOTION TO STAY
`
`I, Steven Seigel, declare under penalty of perjury that the following is true and correct:
`
`1.
`
`I am over the age of twenty-one (21) years and am an associate in the firm of Susman
`
`Godfrey LLP. I am counsel of record for Plaintiff Ancora Technologies, Inc., in the above-captioned
`
`litigation. I submit this declaration in support of Ancora’s Opposition to Defendant Google, LLC’s
`
`Motion to Stay Pending Ex Parte Reexamination.
`
`2.
`
`I am competent to testify as to the matters stated herein, have personal knowledge of
`
`the facts and statements in this declaration, and each of the facts and statements is true and correct.
`
`3.
`
`Attached hereto as Exhibit 1 is a true and correct copy of the Decision of the Patent
`
`Trial and Appeal Board Denying Institution of Covered Business Method Patent Review on
`
`December 1, 2017.
`
`4.
`
`Attached hereto as Exhibit 2 is a true and correct copy of the Decision of the Patent
`
`Trial and Appeal Board Denying Institution of Inter Partes Review and Denying Motion for Joinder
`
`on June 10, 2021.
`
`
`
`
`
`Case 6:21-cv-00735-ADA Document 29-1 Filed 12/30/21 Page 2 of 3
`
`5.
`
`Attached hereto as Exhibit 3 is a true and correct copy of HTC’s Request for Ex Parte
`
`Reexamination transmitted on September 21, 2021.
`
`6.
`
`Attached hereto as Exhibit 4 is a true and correct copy of the Decision Granting Ex
`
`Parte Reexamination of U.S. Patent No. 6,411,941.
`
`7.
`
`Attached hereto as Exhibit 5 is a true and correct copy of the United States Patent and
`
`Trademark Office’s Ex Parte Reexamination Filing Data as of September 30, 2020.
`
`8.
`
`Attached hereto as Exhibit 6 is a true and correct copy of the Petition for Inter Partes
`
`Review of U.S. Patent No. 6,411,941 filed by petitioners Nintendo Co., Ltd., and Nintendo of
`
`America Inc. on August 10, 2021.
`
`9.
`
`Attached hereto as Exhibit 7 is a true and correct copy of Petition for Inter Partes
`
`Review of U.S. Patent No. 6,411,941 filed by petitioners Roku, Inc., and VIZIO, Inc., on August 24,
`
`2021.
`
`10.
`
`Attached hereto as Exhibit 8 is a true and correct copy of Patent Owner’s Preliminary
`
`Response to Petition for Inter Partes Review Under 37 C.F.R. § 42.107 filed on November 18, 2021.
`
`11.
`
`Attached hereto as Exhibit 9 is a true and correct copy of Patent Owner’s Preliminary
`
`Response to Petition for Inter Partes Review Under 37 C.F.R. § 42.107 filed on December 17, 2021.
`
`
`
`Dated: December 30, 2021
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`/s/ Steven M. Seigel
`Andres Healy (WA 45578)
`Steven M. Seigel (admitted pro hac vice)
`SUSMAN GODFREY LLP
`1201 Third Avenue, Suite 3800
`Seattle, Washington 98101
`Tel: (206) 516-3880
`Fax: 206-516-3883
`ahealy@susmangodfrey.com
`sseigel@susmangodfrey.com
`
`
`
`2
`
`
`
`Case 6:21-cv-00735-ADA Document 29-1 Filed 12/30/21 Page 3 of 3
`
`
`Lexie G. White (TX 24048876)
`SUSMAN GODFREY LLP
`1000 Louisiana Street, Suite 5100
`Houston, Texas 77002
`Tel: (713) 651-9366
`Fax: (713) 654-6666
`lwhite@susmangodfrey.com
`
`Charles Ainsworth (TX 00783521)
`Robert Christopher Bunt (TX 00787165)
`PARKER, BUNT & AINSWORTH, P.C.
`100 E. Ferguson, Suite 418
`Tyler, TX 75702
`Tel: (903) 531-3535
`charley@pbatyler.com
`rcbunt@pbatyler.com
`
`COUNSEL FOR PLAINTIFF ANCORA
`TECHNOLOGIES, INC.
`
`
`
`3
`
`
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