Overture Services, Inc. v. Google Inc. Doc.

193
Case 3:02-cv-01991-JSW Document 193 Filed 07/09/2004 Page 1 of 2

1 KEKER & VAN NEST, LLP

JOHN W. KEKER - #49092
2 DARALYN J. DURIE - #169825
CHRISTINE P. SUN - #218701
3 RAVIND S. GREWAL - #220543
710 Sansome Street
4 San Francisco, CA 94111-1704
Telephone: (415) 391-5400
5 Facsimile: (415) 397-7188

6 Attorneys for Defendant and Counterclaimant

GOOGLE INC.
7

8 UNITED STATES DISTRICT COURT

9 NORTHERN DISTRICT OF CALIFORNIA

10 SAN FRANCISCO DIVISION

11

12 OVERTURE SERVICES, INC., Case No. C 02-01991 JSW (EDL)

13 Plaintiff and Counterdefendant, DECLARATION OF CHRISTINE P. SUN

IN SUPPORT OF MOTION TO COMPEL
14 v. PRODUCTION OF DOCUMENTS AND
TESTIMONY RE: PROSECUTION OF
15 GOOGLE INC., ‘361 PATENT (WITHOUT EXHIBITS)
16 Defendant and Counterclaimant. Date: August 10, 2004
Time: 9:00 a.m.
17 Courtroom: 2, 15th Floor
Judge: Hon. Elizabeth D. Laporte
18

19

20
PUBLICLY FILED VERSION
21 (WITHOUT EXHIBITS)

22

23

24

25

26

27

28

DECLARATION OF CHRISTINE P. SUN IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF

334935.01 DOCUMENTS AND TESTIMONY RE: PROSECUTION OF ‘361 PATENT (WITHOUT EXHIBITS)
CASE NO. C 02-01991 JSW (EDL)
Dockets.Justia.com
 Case 3:02-cv-01991-JSW Document 193 Filed 07/09/2004 Page 2 of 2

1 I, CHRISTINE P. SUN, declare as follows:

2 1. I am an attorney licensed to practice in the State of California and am an associate

3 at the law firm of Keker & Van Nest, LLP, counsel for Defendant and Counterclaimant Google

4 Inc. in this matter.

5 2. Attached hereto as Exhibit A is a true and correct copy of a document entitled

6 “February 1998 Goto.com Business Plan,” (THD 132-180).

7 3. Attached hereto as Exhibit B is a true and correct copy of emails that were

8 attached to a document entitled “March 1998 Goto.com Business Plan,” (OVG 47263-47271).

9 4. Attached hereto as Exhibit C is a true and correct copy of excerpts from the May

10 20, 2003 deposition of Darren J. Davis, and the errata sheet for that deposition.

11 5. Attached hereto as Exhibit D is a true and correct copy of excerpts from the July

12 18, 2003 deposition of Elaine K. Lee.

13 6. Attached hereto as Exhibit E is a true and correct copy of excerpts from the July

14 23, 2003 deposition of John Rauch, and the errata sheet for that deposition.

15 7. Attached hereto as Exhibit F is a true and correct copy of a report entitled “Line

16 Ad Totals: Clients by Name, May 1998” (OVGE 175429-175448), exhibit 41 from the April 27,

17 2004 deposition of Overture’s 30(b)(6) witness.

18 8. Attached hereto as Exhibit G is a true and correct copy of a report entitled

19 “Toyota, May 1998” (OVGE 176844-176847), exhibit 43 from the April 27, 2004 deposition

20 Overture’s 30(b)(6) witness.

21 I declare under penalty of perjury under the laws of the United States that the foregoing is

22 true and correct. Executed this 9th day of July, 2004, at San Francisco, California.

23

24 /s/ Christine P. Sun

CHRISTINE P. SUN
25

26

27

28
1
DECLARATION OF CHRISTINE P. SUN IN SUPPORT OF MOTION TO COMPEL PRODUCTION OF
334935.01 DOCUMENTS AND TESTIMONY RE: PROSECUTION OF ‘361 PATENT (WITHOUT EXHIBITS)
CASE NO. C 02-01991 JSW (EDL)