I, Eugene Mar, declare:
1. I am licensed to practice law in California and an associate with the law firm of Farella Braun + Martel LLP, attorneys for Technology Properties Ltd. (“TPL”) and Alliacense Ltd. (collectively, “Defendants”). I have personal knowledge of the matters set forth below and if called and sworn as a witness, I could and would competently testify to the facts set forth herein.
2. Attached hereto as Exhibit A is a true and correct copy of the June 15, 2007 Memorandum Opinion and Order in the matter of TPL v. Fujitsu Ltd., et al., Case No. 2:05-CV-0494 (E.D. Tex.).
3. Attached hereto as Exhibit B is a true and correct copy of U.S. Patent 5,809,336 (‘336), issued September 15, 1998.
4. Attached hereto as Exhibit C is a true and correct copy of the Amendment included in the ‘ 336 Prosecution History, mailed April 11, 1996.
5. Attached hereto as Exhibit D is a true and correct copy of the Amendment included in the ‘336 Prosecution History, mailed January 8, 1997.
6. Attached hereto as Exhibit E is a true and correct copy of the Amendment included in the ‘336 Prosecution History, mailed July 3, 1997.
7. Attached hereto as Exhibit F is a true and correct copy of the Amendment included in the ‘336 Reexamination History, dated September 2, 2008.
8. Attached hereto as Exhibit G is a true and correct copy of the Amendment included in the ‘336 Reexamination History, dated May 12, 2009.
9. Attached hereto as Exhibit H is a true and correct copy of the Ex Parte Reexamination Certificate included in the ‘336 Reexamination History, issued
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Seems to be an attempt to counter Plaintiff claim for Summary Judgement. Perhaps Plaintiffs use same chip design as Fujitsu?
Just speculation on my part.
