Match Group, LLC v. Bumble Trading Inc.

Western District of Texas, txwd-6:2018-cv-00080

Affidavit of Rose Whelan

Interested in this case?

Current View

Full Text

IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS WACO DIVISION MATCH GROUP, LLC, Plaintiff, v. Civil Action No. 6:18-cv-00080-ADA BUMBLE TRADING, INC., and BUMBLE HOLDING, LTD. Defendants. DECLARATION OF ROSE WHELAN IN SUPPORT OF DEFENDANTS' OPENING CLAIM CONSTRUCTION BRIEF I Rose Whelan, hereby declare: 1. I am an attorney with Cooley LLP, attorneys for defendants Bumble Trading, Inc. and Bumble Holding, Ltd. I have personal knowledge of the facts set forth in this declaration and, if called to testify as a witness, could and would testify competently thereto. 2. I submit this declaration in support of Defendants Bumble Trading, Inc. and Bumble Holding, Ltd.'s (collectively, "Bumble") Opening Claim Construction Brief. 3. Attached hereto as Exhibit 1 is a true and correct copy of U.S. Patent No. 9,733,811 (the "ʼ811 Patent"). 4. Attached hereto as Exhibit 2 is a true and correct copy of U.S. Patent No. 9,959,023 (the "ʼ023 Patent"). 5. Attached hereto as Exhibit 3 is a true and correct copy of U.S. Patent No. 10,203,854 (the "ʼ854 Patent"). 6. Attached hereto as Exhibit 4 is a true and correct copy of an excerpt from the Oxford Dictionary of English (3rd Edition, 2010) provided by Match. 7. Attached hereto as Exhibit 5 is a true and correct copy of an excerpt from the Authoritative Dictionary of IEEE Standards Terms (7th Edition, 2000) provided by Match. 8. Attached hereto as Exhibit 6 is a true and correct copy of an excerpt of the Merriam- Webster's Collegiate Dictionary (11th Edition, 2014) provided by Match. 9. Attached hereto as Exhibit 7 is a true and correct copy of an excerpt of the ʼ811 Patent prosecution history produced by Match. 10. Attached hereto as Exhibit 8 is a true and correct copy of an excerpt of the ʼ854 Patent prosecution history produced by Match. 11. Attached hereto as Exhibit 9 is a true and correct copy of an excerpt from the Merriam- Webster Collegiate Dictionary (11th Edition, 2014). 12. Attached hereto as Exhibit 10 is a true and correct copy of an excerpt of the Collins English Dictionary (11th Edition, 2011). I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge, information, and belief. Dated: April 26, 2019 /s/ Rose Whelan Rose Whelan 2