Case 1:10-cv-00432-LAK -AJP Document 166
Filed 04/01/11 Page 1 of 18
CONFIDENTIAL – ATTORNEYS’ EYES ONLY
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF NEW YORK
WI-LAN INC.,
Plaintiff,
v.
LG ELECTRONICS, INC. and LG
ELECTRONICS U.S.A., INC.,
Defendants.
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10 Civ. 432 (LAK) (AJP)
DECLARATION OF MATTHEW C. HOLOHAN IN SUPPORT OF
PLAINTIFF WI-LAN INC.’S MOTION FOR PARTIAL SUMMARY JUDGMENT
I, Matthew C. Holohan, declare as follows:
1.
I am an associate at Kilpatrick Townsend & Stockton LLP. The following facts
are within my personal knowledge and if called as a witness by the Court, I would be competent
to testify to the matters set forth below.
2.
Attached hereto as Exhibit 1 is a true and correct copy of U.S. Patent No.
5,848,402.
3.
Attached hereto as Exhibit 2 is a true and correct copy of the prosecution file
history of U.S. Patent No. 5,828,402, bates numbered WL0220247-WL0220425.
4.
Attached hereto as Exhibit 3 is a true and correct copy of the prosecution file
history of U.S. Patent Application No. 08-667030, bates numbered LG041593-LG041755.
5.
Attached hereto as Exhibit 4 is a true and correct copy of United States Patent
No. 4,554,584, bates numbered WL0000992-WL000104.
6.
Attached hereto as Exhibit 5 is a true and correct copy of United States Patent
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CONFIDENTIAL – ATTORNEYS’ EYES ONLY
No. 5,387,942, bates numbered WL0004309-WL004314.
7.
Attached hereto as Exhibit 6 is a true and correct copy of United States Patent
No. 5,550,575, bates numbered LG043358-LG043376.
8.
Attached hereto as Exhibit 7 is a true and correct copy of excerpts from ATSC
Standard: Program and System Information Protocol for Terrestrial Broadcast and Cable Doc.
A/65, bates numbered ATSC145546-ATSC145642.
9.
Attached hereto as Exhibit 8 is a true and correct copy of excerpts fromATSC
Standard: Program and System Information Protocol for Terrestrial Broadcast and Cable
(Revision A) Doc. A/65A and Amendments No. 1A, 2, and 3, bates numbered LG112100LG112295.
10.
Attached hereto as Exhibit 9 is a true and correct copy of excerpts from ATSC
Standard: Program and System Information Protocol for Terrestrial Broadcast and Cable
(Revision B) Doc. A/65B, bates numbered WL0215259-WL0215416.
11.
Attached hereto as Exhibit 10 is a true and correct copy of excerpts from ATSC
Standard: Program and System Information Protocol for Terrestrial Broadcast and Cable
(Revision C) Doc. A/65C.
12.
Attached hereto as Exhibit 11 is a true and correct copy of excerpts from ATSC
Standard: Program and System Information Protocol for Terrestrial Broadcast and Cable (PSIP)
dated April 14, 2009.
13.
Attached hereto as Exhibit 12 is a true and correct copy of Excepts from the
deposition of Eun-Hyung (Jeffrey) Cho dated October 8, 2010.
14.
Attached hereto as Exhibit 13 is a true and correct copy of Excerpts from the
individual deposition of Timothy Collings dated October 14, 2010.
63238407 v1
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CONFIDENTIAL – ATTORNEYS’ EYES ONLY
15.
Attached hereto as Exhibit 14 is a true and correct copy of Excerpts from the
Rule 30(b)(6) deposition of Timothy Collings dated October 15, 2010.
16.
Attached hereto as Exhibit 15 is a true and correct copy of Excerpts from the
Rule 30(b)(6) deposition of Timothy Collings dated December 7, 2010.
17.
Attached hereto as Exhibit 16 is a true and correct copy of Excerpts from the
individual deposition of Timothy Collings dated December 8, 2010.
18.
Attached hereto as Exhibit 17 is a true and correct copy of Excerpts from the
Rule 30(b)(6) deposition of Timothy Collings dated December 8, 2010.
19.
Attached hereto as Exhibit 18 is a true and correct copy of Excerpts from the
deposition of Murray Eldon dated December 2, 2010.
20.
Attached hereto as Exhibit 19 is a true and correct copy of Excerpts from the
deposition of Michael Fortkort dated October 27, 2010.
21.
Attached hereto as Exhibit 20 is a true and correct copy of Excerpts from the
deposition of Dominic Perri dated March 15, 2011.
22.
Attached hereto as Exhibit 21 is a true and correct copy of Excerpts from the
deposition of Najmul Siddiqui dated December 3, 2010.
23.
Attached hereto as Exhibit 22 is a true and correct copy of the Declaration of
Bernard J. Lechner (without exhibits).
24.
Attached hereto as Exhibit 23 is a true and correct copy of the Declaration of
Jeffrey S. Hamilton (without exhibits).
25.
Attached hereto as Exhibit 24 is a true and correct copy of the Expert Report on
Invalidity by Adam Goldberg dated January 14, 2011 (without exhibits).
26.
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Attached hereto as Exhibit 25 is a true and correct copy of the Opening Expert
-3-
Case 1:10-cv-00432-LAK -AJP Document 166
Filed 04/01/11 Page 4 of 18
CONFIDENTIAL – ATTORNEYS’ EYES ONLY
Report and Disclosure of Michele M. Riley Under Rule 26(a)(2)(B), Fed. R. Civ. P. (without
exhibits).
27.
Attached hereto as Exhibit 26 is a true and correct copy of the Opening Expert
Report and Disclosure of Michele M. Riley Under Rule 26(a)(2)(B), Fed. R. Civ. P., Exhibit 8.
28.
Attached hereto as Exhibit 27 is a true and correct copy of excerpts from the
transcript of a Hearing before this Court on February 10, 2011.
29.
Attached hereto as Exhibit 28 is a true and correct copy of Defendants’
Supplemental Initial Disclosures.
30.
Attached hereto as Exhibit 29 is a true and correct copy of Defendant LG
Electronics, Inc.’s (“LGE”) Responses and Objections to Plaintiff’s Fourth Set of Interrogatories.
31.
Attached hereto as Exhibit 30 is a true and correct copy of Defendant LG
Electronics U.S.A., Inc.’s (“LGEUS”) Responses and Objections to Plaintiff’s Fourth Set of
Interrogatories.
32.
Attached hereto as Exhibit 31 is a true and correct copy of the document bates
numbered ATSC066694-ATSC066696.
33.
Attached hereto as Exhibit 32 is a true and correct copy of the document bates
numbered ATSC099363-ATSC099449.
34.
Attached hereto as Exhibit 33 is a true and correct copy of the document bates
numbered ATSC183798-ATSC183835.
35.
Attached hereto as Exhibit 34 is a true and correct copy of the document bates
numbered ATSC185154.
36.
Attached hereto as Exhibit 35 is a true and correct copy of the document bates
numbered ATSC184493-ATSC184600.
63238407 v1
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CONFIDENTIAL – ATTORNEYS’ EYES ONLY
37.
Attached hereto as Exhibit 36 is a true and correct copy of the document bates
numbered ATSC190172.
38.
Attached hereto as Exhibit 37 is a true and correct copy of the document bates
numbered ATSC260081-ATSC260109.
39.
Attached hereto as Exhibit 38 is a true and correct copy of the document bates
numbered ATSC269929-ATSC269933.
40.
Attached hereto as Exhibit 39 is a true and correct copy of the document bates
numbered CEA003664-CEA003665.
41.
Attached hereto as Exhibit 40 is a true and correct copy of the document bates
numbered CEA003697-CEA003698.
42.
Attached hereto as Exhibit 41 is a true and correct copy of the document bates
numbered CEA004755-CEA004757.
43.
Attached hereto as Exhibit 42 is a true and correct copy of the document bates
numbered CEA005941-CEA005942.
44.
Attached hereto as Exhibit 43 is a true and correct copy of the document bates
numbered LG041581-LG041591.
45.
Attached hereto as Exhibit 44 is a true and correct copy of the document bates
numbered LG043699-LG043717.
46.
Attached hereto as Exhibit 45 is a true and correct copy of the document bates
numbered LG048758-LG048764.
47.
Attached hereto as Exhibit 46 is a true and correct copy of the document bates
numbered LG048782-LG048783.
48.
63238407 v1
Attached hereto as Exhibit 47 is a true and correct copy of the document bates
-5-
Case 1:10-cv-00432-LAK -AJP Document 166
Filed 04/01/11 Page 6 of 18
CONFIDENTIAL – ATTORNEYS’ EYES ONLY
numbered LG048784.
49.
Attached hereto as Exhibit 48 is a true and correct copy of the document bates
numbered LG048786-LG048795.
50.
Attached hereto as Exhibit 49 is a true and correct copy of the document bates
numbered LG048799-LG048801.
51.
Attached hereto as Exhibit 50 is a true and correct copy of the document bates
numbered LG048802.
52.
Attached hereto as Exhibit 51 is a true and correct copy of the document bates
numbered LG048818.
53.
Attached hereto as Exhibit 52 is a true and correct copy of the document bates
numbered LG048833-LG048834.
54.
Attached hereto as Exhibit 53 is a true and correct copy of the document bates
numbered LG048835-LG048836.
55.
Attached hereto as Exhibit 54 is a true and correct copy of the document bates
numbered LG048862-LG048863.
56.
Attached hereto as Exhibit 55 is a true and correct copy of the document bates
numbered LG049105-LG049106.
57.
Attached hereto as Exhibit 56 is a true and correct copy of the document bates
numbered LG058351-LG058367.
58.
Attached hereto as Exhibit 57 is a true and correct copy of the document bates
numbered LG069464-LG069473.
59.
Attached hereto as Exhibit 58 is a true and correct copy of the document bates
numbered LG072475-LG072476.
63238407 v1
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CONFIDENTIAL – ATTORNEYS’ EYES ONLY
60.
Attached hereto as Exhibit 59 is a true and correct copy of the document bates
numbered LG072607-LG072611.
61.
Attached hereto as Exhibit 60 is a true and correct copy of the document bates
numbered LG072940.
62.
Attached hereto as Exhibit 61 is a true and correct copy of the document bates
numbered LG072941-LG072942.
63.
Attached hereto as Exhibit 62 is a true and correct copy of the document bates
numbered LG073238-LG073240.
64.
Attached hereto as Exhibit 63 is a true and correct copy of the document bates
numbered LG073259-LG073263.
65.
Attached hereto as Exhibit 64 is a true and correct copy of the document bates
numbered LG073264-LG073266.
66.
Attached hereto as Exhibit 65 is a true and correct copy of the document bates
numbered LG073285-LG073290.
67.
Attached hereto as Exhibit 66 is a true and correct copy of the document bates
numbered LG073342-LG073343.
68.
Attached hereto as Exhibit 67 is a true and correct copy of the document bates
numbered LG073372.
69.
Attached hereto as Exhibit 68 is a true and correct copy of the document bates
numbered LG073392-LG073393.
70.
Attached hereto as Exhibit 69 is a true and correct copy of the document bates
numbered LG073396-LG073398.
71.
63238407 v1
Attached hereto as Exhibit 70 is a true and correct copy of the document bates
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Case 1:10-cv-00432-LAK -AJP Document 166
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CONFIDENTIAL – ATTORNEYS’ EYES ONLY
numbered LG073399-LG073401.
72.
Attached hereto as Exhibit 71 is a true and correct copy of the document bates
numbered LG073420-LG073423.
73.
Attached hereto as Exhibit 72 is a true and correct copy of the document bates
numbered LG073565-LG073569.
74.
Attached hereto as Exhibit 73 is a true and correct copy of the document bates
numbered LG074247.
75.
Attached hereto as Exhibit 74 is a true and correct copy of the document bates
numbered LG074314-LG074319, and a translation of the same obtained by Plaintiff Wi-LAN
Inc. (“Wi-LAN”).
76.
Attached hereto as Exhibit 75 is a true and correct copy of the document bates
numbered LG075127-LG075128.
77.
Attached hereto as Exhibit 76 is a true and correct copy of the document bates
numbered LG075141-LG075144.
78.
Attached hereto as Exhibit 77 is a true and correct copy of the document bates
numbered LG075226.
79.
Attached hereto as Exhibit 78 is a true and correct copy of the document bates
numbered LG075259-LG075263.
80.
Attached hereto as Exhibit 79 is a true and correct copy of the document bates
numbered LG075569-LG075572.
81.
Attached hereto as Exhibit 80 is a true and correct copy of the document bates
numbered LG076548-LG076549.
82.
63238407 v1
Attached hereto as Exhibit 81 is a true and correct copy of the document bates
-8-
Case 1:10-cv-00432-LAK -AJP Document 166
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CONFIDENTIAL – ATTORNEYS’ EYES ONLY
numbered LG077131-LG077162.
83.
Attached hereto as Exhibit 82 is a true and correct copy of the document bates
numbered LG077601-LG077603.
84.
Attached hereto as Exhibit 83 is a true and correct copy of the document bates
numbered LG078102-LG078118.
85.
Attached hereto as Exhibit 84 is a true and correct copy of the document bates
numbered LG078246.
86.
Attached hereto as Exhibit 85 is a true and correct copy of the document bates
numbered LG078574-LG078591.
87.
Attached hereto as Exhibit 86 is a true and correct copy of the document bates
numbered LG078592-LG078618.
88.
Attached hereto as Exhibit 87 is a true and correct copy of the document bates
numbered LG078707-LG078723.
89.
Attached hereto as Exhibit 88 is a true and correct copy of the document bates
numbered LG078724-LG078752.
90.
Attached hereto as Exhibit 89 is a true and correct copy of the document bates
numbered LG078780-LG078796.
91.
Attached hereto as Exhibit 90 is a true and correct copy of the document bates
numbered LG078797.
92.
Attached hereto as Exhibit 91 is a true and correct copy of the document bates
numbered LG078863.
93.
Attached hereto as Exhibit 92 is a true and correct copy of the document bates
numbered LG079089-LG079107.
63238407 v1
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94.
Attached hereto as Exhibit 93 is a true and correct copy of the document bates
numbered LG079108.
95.
Attached hereto as Exhibit 94 is a true and correct copy of the document bates
numbered LG081688.
96.
Attached hereto as Exhibit 95 is a true and correct copy of the document bates
numbered LG112385-LG112387.
97.
Attached hereto as Exhibit 96 is a true and correct copy of the document bates
numbered LG112581-LG112585.
98.
Attached hereto as Exhibit 97 is a true and correct copy of the document bates
numbered LG123356-LG123361, plus a translation of the same obtained by Wi-LAN.
99.
Attached hereto as Exhibit 98 is a true and correct copy of the document bates
numbered LG123399-LG123407, plus a translation of the same obtained by Wi-LAN.
100.
Attached hereto as Exhibit 99 is a true and correct copy of the document bates
numbered WL0000392-WL0000415.
101.
Attached hereto as Exhibit 100 is a true and correct copy of the document bates
numbered WL0001893-WL0001896.
102.
Attached hereto as Exhibit 101 is a true and correct copy of the document bates
numbered WL0004282-WL0004283.
103.
Attached hereto as Exhibit 102 is a true and correct copy of the document bates
numbered WL0006666-WL0006700.
104.
Attached hereto as Exhibit 103 is a true and correct copy of the document bates
numbered WL0007548-WL0007550.
105.
63238407 v1
Attached hereto as Exhibit 104 is a true and correct copy of the document bates
- 10 -
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numbered WL0007578-WL0007579.
106.
Attached hereto as Exhibit 105 is a true and correct copy of the document bates
numbered WL0007657-WL0007664.
107.
Attached hereto as Exhibit 106 is a true and correct copy of the document bates
numbered WL0007665-WL0007672.
108.
Attached hereto as Exhibit 107 is a true and correct copy of the document bates
numbered WL0007910-WL0007912.
109.
Attached hereto as Exhibit 108 is a true and correct copy of the document bates
numbered WL0013831-WL0013836.
110.
Attached hereto as Exhibit 109 is a true and correct copy of the document bates
numbered WL0013837-WL0013843.
111.
Attached hereto as Exhibit 110 is a true and correct copy of the document bates
numbered WL0014249-WL0014254.
112.
Attached hereto as Exhibit 111 is a true and correct copy of the document bates
numbered WL0014255.
113.
Attached hereto as Exhibit 112 is a true and correct copy of the document bates
numbered WL0014289-WL0014290.
114.
Attached hereto as Exhibit 113 is a true and correct copy of the document bates
numbered WL0014468-WL0014475.
115.
Attached hereto as Exhibit 114 is a true and correct copy of the document bates
numbered WL0014476-WL0014478.
116.
Attached hereto as Exhibit 115 is a true and correct copy of the document bates
numbered WL0015872-WL015913.
63238407 v1
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117.
Attached hereto as Exhibit 116 is a true and correct copy of the document bates
numbered WL0017733-WL0017795.
118.
Attached hereto as Exhibit 117 is a true and correct copy of the document bates
numbered WL0032175-WL0032176.
119.
Attached hereto as Exhibit 118 is a true and correct copy of the document bates
numbered WL0032177-WL0032180.
120.
Attached hereto as Exhibit 119 is a true and correct copy of the document bates
numbered WL0041576-WL0041578.
121.
Attached hereto as Exhibit 120 is a true and correct copy of the document bates
numbered WL0053933-WL0053939.
122.
Attached hereto as Exhibit 121 is a true and correct copy of the document bates
numbered WL0054036-WL0054045.
123.
Attached hereto as Exhibit 122 is a true and correct copy of the document bates
numbered WL0076485-WL0076509.
124.
Attached hereto as Exhibit 123 is a true and correct copy of the document bates
numbered WL0107962-WL0108069.
125.
Attached hereto as Exhibit 124 is a true and correct copy of the document bates
numbered WL0111219.
126.
Attached hereto as Exhibit 125 is a true and correct copy of the document bates
numbered WL0111235.
127.
Attached hereto as Exhibit 126 is a true and correct copy of the document bates
numbered WL0111236-WL0111237.
128.
63238407 v1
Attached hereto as Exhibit 127 is a true and correct copy of the document bates
- 12 -
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numbered WL0113052-WL0113053.
129.
Attached hereto as Exhibit 128 is a true and correct copy of the document bates
numbered WL0113492-WL0113503.
130.
Attached hereto as Exhibit 129 is a true and correct copy of the document bates
numbered WL0115331.
131.
Attached hereto as Exhibit 130 is a true and correct copy of the document bates
numbered WL0121399-WL0121400.
132.
Attached hereto as Exhibit 131 is a true and correct copy of the document bates
numbered WL0124099.
133.
Attached hereto as Exhibit 132 is a true and correct copy of the document bates
numbered WL0124100-WL0124101.
134.
Attached hereto as Exhibit 133 is a true and correct copy of the document bates
numbered WL0124180-WL0124185.
135.
Attached hereto as Exhibit 134 is a true and correct copy of the document bates
numbered WL0124223-WL0124234.
136.
Attached hereto as Exhibit 135 is a true and correct copy of the document bates
numbered WL0124418-WL0124421.
137.
Attached hereto as Exhibit 136 is a true and correct copy of the document bates
numbered WL0124536.
138.
Attached hereto as Exhibit 137 is a true and correct copy of the document bates
numbered WL0124537-WL0124540.
139.
Attached hereto as Exhibit 138 is a true and correct copy of the document bates
numbered WL0124585-WL0124586.
63238407 v1
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140.
Attached hereto as Exhibit 139 is a true and correct copy of the document bates
numbered WL0124587-WL0124588.
141.
Attached hereto as Exhibit 140 is a true and correct copy of the document bates
numbered WL0124589-WL0124590.
142.
Attached hereto as Exhibit 141 is a true and correct copy of the document bates
numbered WL0129016-WL0129020.
143.
Attached hereto as Exhibit 142 is a true and correct copy of the document bates
numbered WL0129217-WL0129273.
144.
Attached hereto as Exhibit 143 is a true and correct copy of the document bates
numbered WL0129572-WL0129575.
145.
Attached hereto as Exhibit 144 is a true and correct copy of the document bates
numbered WL0167847-WL0167848.
146.
Attached hereto as Exhibit 145 is a true and correct copy of the document bates
numbered WL0167942-WL0167985.
147.
Attached hereto as Exhibit 146 is a true and correct copy of the document bates
numbered WL0168435-WL0168438.
148.
Attached hereto as Exhibit 147 is a true and correct copy of the document bates
numbered WL0171035-WL0171043.
149.
Attached hereto as Exhibit 148 is a true and correct copy of the document bates
numbered WL0171447.
150.
Attached hereto as Exhibit 149 is a true and correct copy of the document bates
numbered WL0171448-WL0171451.
151.
63238407 v1
Attached hereto as Exhibit 150 is a true and correct copy of the document bates
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numbered WL0215141-WL0215194.
152.
Attached hereto as Exhibit 151 is a true and correct copy of the document bates
numbered WL0215417-WL0215450.
153.
Attached hereto as Exhibit 152 is a true and correct copy of the document bates
numbered WL0215486-WL0215521.
154.
Attached hereto as Exhibit 153 is a true and correct copy of the document bates
numbered WL0223779.
155.
Attached hereto as Exhibit 154 is a true and correct copy of the document bates
numbered WL0223780.
156.
Attached hereto as Exhibit 155 is a true and correct copy of the document bates
numbered WL0223781.
157.
Attached hereto as Exhibit 156 is a true and correct copy of the document bates
numbered WL0223782.
158.
Attached hereto as Exhibit 157 is a true and correct copy of the document bates
numbered WL0223806.
159.
Attached hereto as Exhibit 158 is a true and correct copy of the document bates
numbered WL0228480.
160.
Attached hereto as Exhibit 159 is a true and correct copy of the document bates
numbered WL0228513.
161.
Attached hereto as Exhibit 160 is a true and correct copy of the document bates
numbered WL0228514.
162.
Attached hereto as Exhibit 161 is a true and correct copy of the document bates
numbered WL0228531.
63238407 v1
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163.
Attached hereto as Exhibit 162 is a true and correct copy of the document bates
numbered WL0304878-WL0304886.
164.
Attached hereto as Exhibit 163 is a true and correct copy of the document bates
numbered WL0304968-WL0304994.
165.
Attached hereto as Exhibit 164 is a true and correct copy of the document bates
numbered WL0316043-WL0316065.
166.
Attached hereto as Exhibit 165 is a true and correct copy of the document bates
numbered WL0316080-WL0316088.
167.
Attached hereto as Exhibit 166 is a true and correct copy of the document bates
numbered WL0316270-WL0316277.
168.
Attached hereto as Exhibit 167 is a true and correct copy of the document bates
numbered WL0376367-WL0376368.
169.
Attached hereto as Exhibit 168 is a true and correct copy of the document bates
numbered WL0384205-WL0384210.
170.
Attached hereto as Exhibit 169 is a true and correct copy of the document bates
numbered WL0384514-WL0384526.
171.
Attached hereto as Exhibit 170 is a true and correct copy of the document bates
numbered WL0430331-WL0430332.
172.
Attached hereto as Exhibit 171 is a true and correct copy of the document bates
numbered WL0434249-WL0434258.
173.
Attached hereto as Exhibit 172 is a true and correct copy of the document bates
numbered WL0434259-WL0434268.
174.
63238407 v1
Attached hereto as Exhibit 173 is a true and correct copy of the document bates
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numbered WL0437463.
175.
Attached hereto as Exhibit 174 is a true and correct copy of the document bates
numbered WL0437464.
176.
Attached hereto as Exhibit 175 is a true and correct copy of the document bates
numbered WL0437465.
177.
Attached hereto as Exhibit 176 is a true and correct copy of the document bates
numbered WL0437466.
178.
Attached hereto as Exhibit 177 is a true and correct copy of the document bates
numbered WL0437467.
179.
Attached hereto as Exhibit 178 is a true and correct copy of the document bates
numbered LG091441-LG091480.
180.
Attached hereto as Exhibit 179 is a true and correct copy of Plaintiff Wi-LAN
Inc.’s First Amended Response to Defendant LG Electronics, Inc.’s Interrogatory No. 3.
181.
Attached hereto as Exhibit 180 is a true and correct copy of the document bates
numbered CEA003706-CEA003728.
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