Bicameral LLC v. NXP USA, Inc. et al

Western District of Texas, txwd-6:2018-cv-00294

Affidavit Kheyfits Declaration

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION BICAMERAL LLC, Plaintiff, Case No. 6:18-cv-00294-ADA v. JURY TRIAL DEMANDED NXP USA, INC., NXP SEMICONDUCTORS N.V. AND NXP B.V., Defendants. DECLARATION BY DMITRY KHEYFITS I, Dmitry Kheyfits, declare as follows: 1. I am a partner at Kheyfits Belenky LLP, attorneys for the Plaintiff in this matter, Bicameral LLC. I have personal knowledge of the facts set forth in this declaration and could testify competently to those facts. 2. Exhibit 1 is a true and correct copy of U.S. Patent No. 6,321,331 entitled, "Real Time Debugger Interface For Embedded Systems." 3. Exhibit 2 is a true and correct copy of U.S. Patent No. 6,639,538 entitled, "Real-Time Transient Pulse Monitoring System And Method." 4. Exhibit 3 is a true and correct copy of Excerpts from the File History of the Re- Examination of U.S. Patent No. 6,321,331. 5. Exhibit 4 is a true and correct copy of an excerpt from Defendants Invalidity Contentions. 6. Exhibit 5 is a true and correct copy of an Excerpt from the File History of the U.S. Patent No. 6,321,331 7. Exhibit 6 is a true and correct copy of U.S. Patent No. 9,626,280. -1- 8. Exhibit 7 is a true and correct copy of U.S. Patent Application No. 09/064,474 from the file history of U.S. Patent No. 6,321,331. Dated: August 12, 2019 /s/ Dmitry Kheyfits Dmitry Kheyfits -2-