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 8 is a true and correct copy of Defendants' Disclosure of Proposed Claim Constructions dated July 23, 2019. 3. Exhibit 9 is a true and correct copy of U.S. Patent No. 5,996,092 to Augsburg et al. excerpted from the reexamination file history (No. 90/011,532) of U.S. Patent No. 6,321,331. Dated: September 3, 2019 /s/ Dmitry Kheyfits Dmitry Kheyfits -1-