3rd Pacer--DECLARATION OF KYLE CHEN IN SUPPORT OF HTC’S ADMINISTRATIVE MOTION TO FILE CONFIDENTIAL EXHIBITS UNDER SEAL
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wolfpackvoltare
E-Filed on Saturday 4/9/2011
UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA
SAN JOSE DIVISION
HTC CORPORATION, HTC AMERICA,
INC.,
Plaintiffs,
v.
TECHNOLOGY PROPERTIES LIMITED, PATRIOT SCIENTIFIC CORPORATION, and ALLIACENSE
LIMITED,
Defendants.
DECLARATION OF KYLE CHEN IN SUPPORT OF HTC’S ADMINISTRATIVE MOTION TO FILE CONFIDENTIAL EXHIBITS UNDER SEAL
I, Kyle Chen, declare:
1. I am an attorney at the law firm of Cooley LLP, counsel in this action for Plaintiffs HTC Corporation and HTC America, Inc. (collectively, “Plaintiffs”). I make this declaration in support of Plaintiffs’ Administrative Motion To File Confidential Exhibits Under Seal. I have personal knowledge of the facts contained within this declaration, and if called as a witness, can
testify competently to the matters contained herein.
2. Exhibit 3 to the Declaration of Kyle Chen in Support of HTC’s Notice of Motion and Motion for Summary Judgment of Non-Infringement of U.S. Patent Nos. 5,440,749, 5,809,336 and 6,598,148 is Defendants’ claim chart in their Infringement Contentions for U.S. Patent No. 5,440,749 against HTC Star Trek 3125. This document was designated by Defendants s “Confidential.”
3. Exhibit 4 to the Declaration of Kyle Chen in Support of HTC’s Notice of Motion and Motion for Summary Judgment of Non-Infringement of U.S. Patent Nos. 5,440,749, 5,809,336 and 6,598,148 is TPL’s claim chart in its Infringement Contentions for U.S. Patent No. 5,809,336 against HTC Wing. This document was designated by Defendants as “Confidential.”
4. Exhibit 5 to the Declaration of Kyle Chen in Support of HTC’s Notice of Motion and Motion for Summary Judgment of Non-Infringement of U.S. Patent Nos. 5,440,749, 5,809,336 and 6,598,148 is TPL’s claim chart in its Infringement Contentions for U.S. Patent No. 6,598,148 against HTC Advantage X7501. This document was designated by Defendants as “Confidential.”
5. On Friday, April 8, 2011, I contacted Eugene Mar, counsel for Defendants, to confirm that Defendants would not oppose filing the above-referenced exhibits under seal. Mr. Mar agreed that Defendants would that not oppose such a motion.
I declare under penalty of perjury that the foregoing is true and correct. Executed on
April 9, 2011 in Palo Alto, California.
/s/_Kyle Chen
Kyle Chen
