Free Redacted Document - District Court of Delaware - Delaware

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IN THE UNITED STATES DISTRICT COURT FOR THE DISTRICT OF DELAWARE

POLAROID CORPORATION, Plaintiff, V. HEWLETT-PACKARD COMPANY, Defendant. C. A. No. 06-738 (SLR) (D.Del.) ).

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DECLARATION OF TEODORO HAASL-MARTINEZ 1. I am employed by Hewlett-Packard Company ("HP") as a software

engineer and technical project manager in the research and development area. I currently work in HP's Vancouver office. I report to Juli Lee. I have been employed by HP for seventeen years. I have a degree in Information Technology. My work ordinarily

involves projects relating to release of new products. I am familiar with the algorithm known as Local Area Contrast Enhancement ("LACE") from my work on HP printer drivers. 2. As explained below, I and others at HP have spent a significant amount of

time making our best effort to reply accurately and fully to discovery requests by Polaroid in this action. 3. Much of my work at HP involves printer drivers. A printer driver is the

software code by which the computer directs the printer what to do.

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6. January 2007.

My involvement in the current lawsuit by Polaroid against HP began in

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My deposition was taken on February 1, 2008, and as noted I have performed substantial additional work in response to questions that Polaroid raised thereafter. If it is deemed necessary to have another deposition concerning my work after February 1, 2008, 1 am willing to appear for another deposition. Likewise, if called as a witness, .1 am prepared to testify at trial. Signed under the pains and penalties of perjury this /day of June, 2008.

Teodoro Haasl-Martinez

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CERTIFICATE OF SERVICE
I hereby certify that on June 12, 2008, I electronically filed with the Clerk of Court the foregoing document using CM/ECF which will send electronic notification of such filing(s) to the following counsel: Via Email Jack B. Blumenfeld (#1014) Julia Heaney (#3052) Morris, Nichols, Arsht & Tunnell, LLP 1201 North Market Street Wilmington, DE 19899-1347 Phone: 302-658-9200 Fax: 302-658-3989 Emails: [email protected]; [email protected] Via Email Russell E. Levine, P.C. Michelle W. Skinner/David W. Higer Maria A. Meginnes/Courtney Holohan/C. Beasley Kirkland & Ellis LLP 200 East Randolph Drive Chicago, IL 60601 Phone: 312-861-2000 Fax: 312-861-2200 Emails: [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected]; [email protected] Courtesy Copy Via Federal Express Michelle W. Skinner Kirkland & Ellis LLP 200 East Randolph Drive Chicago, IL 60601 Phone: 312-861-2000 Fax: 312-861-2200 /s/ Raymond N. Scott, Jr. Raymond N. Scott, Jr. Attorneys for Plaintiff and Counterclaim-Defendant Polaroid Corporation

Attorneys for Plaintiff and Counterclaim-Defendant Polaroid Corporation

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Exhibit A

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