Ixi Mobile (R&D) Ltd. et al v. Apple, Inc.

Northern District of California, cand-4:2015-cv-03755

DECLARATION re: 61 Brief Declaration of Mark W. Halderman. Document filed by IXI IP,LLC, IXI Mobile (R&D) Ltd.

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK IXI MOBILE (R&D) LTD., et al.,: 14-cv-4355 RJS Plaintiffs,: ECF CASE v.:: SAMSUNG ELECTRONICS CO., ET AL.,: Defendants.:: IXI MOBILE (R&D) LTD., et al.,: 14-cv-4428 RJS Plaintiffs,: ECF CASE v.:: BLACKBERRY LTD, et al.,: Defendants.::: 14-cv-7954 RJS IXI MOBILE (R&D) LTD., et al.,: ECF CASE Plaintiffs,: v.:: APPLE INC.: Defendant.:: DECLARATION OF MARK W. HALDERMAN I, Mark W. Halderman, declare as follows: 1. I am an Associate of the law firm Dilworth Paxson LLP ("Dilworth") licensed to practice law in the States of Pennsylvania and Texas and am admitted Pro Hac Vice in the Southern District of New York. I am counsel for Plaintiffs IXI Mobile (R&D), Ltd. ("IXI Mobile") and IXI IP, LLC ("IXI IP") in the above actions. 2. Concurrently with the filing of their Opening Claim Construction Brief and this Declaration, Plaintiffs filed a true and correct copy of the Declaration of Joel Williams dated July 8, 2015 as a separate document. 3. Attached hereto as Exhibit 1 is a true and correct copy of excerpts from The Authoritative Dictionary of IEEE Standards (7th ed. 2000). 4. Attached hereto as Exhibit 2 is a true and correct copy of excerpts from the IBM Dictionary of Computing (10th ed. 1993). 5. Attached hereto as Exhibit 3 is a true and correct copy of excerpts from U.S. Patent No. 6,201,862. 6. Attached hereto as Exhibit 4 is a true and correct copy of excerpts from Newton's Telecomm (17 ed. 2001). 7. Attached hereto as Exhibit 5 is a true and correct copy of excerpts from the Deposition of Peter Fornell dated July 1, 2015 8. Attached here as Exhibit 6 is a true and correct copy of Roget's 21st Century Thesaurus, Third Edition. Philip Lief Group 2009. http://www.thesaurus.com/browse/compose (accessed: July 07, 2015). I declare under penalty of perjury that the foregoing is true and correct to the best of my information, knowledge and belief. /s/ Mark W. Halderman Mark W. Halderman Dated: July 8, 2015 2