Appendix A-30 Responsive Expert Declaration in Support of Claim Construction

• Author: Kenneth Dorsney
• Pages: 833-834

Responsive Expert Declaration in Support of Claim

Construction

IN THE UNITED STATES DISTRICT COURT

[]

[]

I, [Name], declare that the following is true and correct:

I.

1. I am the same [Name] who provided the Original Declaration in Support

of [Plaintiff’s or Defendant’s] Opening Markman

with this Court on [Date

as interpreted by a person having ordinary skill in the art (“PHOSITA”).

2.

addressing arguments raised in [Defendant’s or Plaintiff’s] Opening Markman

addition to opinions provided by [Defendant’s or Plaintiff’s] expert [Name]. [Name]’s

opinions are contained in his Declaration which was filed in support of [Defendant’s or

Plaintiff’s] Opening Markman Cite].

3. Name]

Declaration, [Defendant’s or Plaintiff’s] Opening Markman

[Name] Declaration, as well as [Plaintiff’s or Defendant’s] Opening Markman and

the materials cited in my Original Declaration.

4. upon my review of these materials, my opinion remains that the

constructions proposed by [Plaintiff or Defendant] are the most consistent with the

specification of the ’001 patent and the invention claimed therein and, therefore, should

be adopted by the Court in the Markman claim construction proceeding.

5. Name] Declaration are

provided below. For clarity, the section headings that follow are taken directly from the

[Name] Declaration, and my comments are provided for each of those sections.

II. [

In this section, [Name] outlined his relevant experience and included a

current copy of his curriculum vitae. I reserve my right to comment on [Name]’s

qualifications as needed.

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A-30

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