Free Redacted Document - District Court of Delaware - Delaware

Case 1 :06-cv-00032-JJF Document 178 Filed 08/06/2007 Page 1 of 4
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
RR. DONNELLEY & SONS COMPANY,
Plaintiff]
v. C.A. No. 06-032-JJF
CREO, INC., NEXPRESS SOLUTIONS, INC.,
Kooar; VERSAMARK, mc., sasmaw §E§€I%T§§RSION
KODAK COMPANY, and KODAK GRAPHIC ’
COMMUNICATIONS COMPANY, =
Defendants.
EASTMAN KODAK COMPANY,
Countcrclaim-Plaintiff,
v.
R.R. DONNELLEY & SONS COMPANY,
Counterclaim-Defendarit.
DECLARATION OF NATHANIEL GROW IN SUPPORT OF
KODAK’S CLAIM CONSTRUCTION MEMORANDUM
. I, Nathaniel Grow, declare as follows:
1. I am an attorney at Crowell & Moring LLP, counsel for Defendants Creo, Inc.,
NexPress Solutions, Inc., Kodak Versamark, Inc., Eastman K.odal< Company, and Kodak Graphic
Communications Company. I submit this declaration based on my personal, first-hand
knowledge.
2. Attached hereto as Exhibit A is :1 time and correct copy of Kodak’s Proposed
Claim Construction Order.
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Case 1 :06-cv-00032-JJF Document 178 Filed 08/06/2007 Page 2 of 4
3. Attached hereto as Exhibit B is a true and correct copy of U.S. Patent No.
6,327,559, Bates numbered 1.2.R.D015275—RrRD015307.
4. Attached hereto as Exhibit C is a true and correct copy of U.S. Patent No.
6,844,940, Bates numbered RRD022251-RRD022330.
5. Attached hereto as Exhibit D is a true and correct copy of U.S. Patent No.
6,205,452, Bates numbered K00557566~K.00557654.
6. Attached hereto as Exhibit E is a true and correct copy of U.S. Patent No.
6,952,801, Bates numbered RRD2520L32-R1{D252109.
7. Attached hereto as Exhibit F is a true and correct copy of PENNY K. BENNETT,
HARVEY R. LEVENSON, AND FRANK J. ROMANO, THE HANDBOOK. FOR DIGITAL PRINTING AND
VAR1ABLE—DATA PRINUNG (2006), Bates numbered K.024464l 7—K02446626.
8. Attached as Exhibit G is a true and correct copy of FRANK J. ROMANO, POCKET
Goree ro Dtomxr, Prtsrrtess (1996), Bates numbered K02445393-KO2445568.
9. Attached hereto as Exhibit H is a true and correct copy ofthe Useifs GUIDE TO
FORMS MERGE, Bates numbered K01863184-K01863213.
10. Attached hereto as Exhibit I is a true and correct copy of an Electronic Collaticn
Presentation, Bates numbered RRD017446-RRD017456.
11. Attached hereto as Exhibit I is a true and correct copy of a January 25, 1995
Facsimile from Barco Graphics to R.R. Donnelley, Bates numbered RRD049959.
12. Attached hereto as Exhibit K is a true and correct copy ofthe TARGETJT
Paomacr Dssrou AND Fire PREPARATION Goins ron VARIABLE IMAGE PRINTING, Vansrou 1.0,
September 5, 1995, Bates numbered RRDOH3423-RRD013441.
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Case 1 :06-cv-00032-JJF Document 178 Filed 08/06/2007 Page 3 of 4
13. Attached hereto as Exhibit L is a tmc and correct copy of Plaintiff R.R.
Donnelley’s Third Supplemental Responses to Defendants’ lnterrogatory Nos. 1 and 2, Second
Supplemental Responses to Defendant? Interrogatory Nos. 3, 4, 7 and 9, and Supplemental
Responses to Defendants’ lnterrogatory Nos. 10, ll, 13, 15, 16 and 20, served on July 2, 2007.
14. Attached hereto as Exhibit M is a true and correct copy of excerpts from GEORGE
OMURA, MAsrsR1No AutoCAD RELEASE 12, Bates numbered K02446724, KO2446895—
K02446899, and K.02446913—K02446917.
15. Attached hereto as Exhibit N is a true and correct copy of AMERICAN NATIONAL
STANDARD, GRAPPHC rscrmotoer M VARIABLE PRINTING DATA EXCHANGE Usmo PPML AND
PDF (PPMLN DX), Bates numbered K0070I104-K00701t42.
16. Attached hereto as Exhibit O is a true and correct copy of Plaintiff R.R.
Donne1iey’s Proposed Construction of Identified Claim Terms, served on July 2, 2007.
I'7. Attached hereto as Exhibit P is a true and correct copy of excerpts from the
December 5, 2006, deposition transcript of James L. Warrnus.
I declare under penalty of perjury under the laws ofthe United States of America that the
foregoing is true and correct and that this deciaration was executed on July 30, 2007, in
Washington, DC. -.4-I- , ·`~·

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Case 1 :06-cv-00032-JJF Document 178 Filed 08/06/2007 Page 4 of 4
CERTIFICATE OF SERVICE
l hereby certify that on August 6, 2007, I electronically tiled the foregoing with the Clerk
of Court using CM/ECF which will send notification of such tiling(s) to the following, who have
also been served as noted:
BY HAND DELIVERY
lack B. Blumenfeld, Esquire
Rodger D. Smith, II, Esquire
Morris, Nichols, Arsht & Tunnell
l20l North Market Street
P. O. Box 1347
Wilmington, DB 19899
I hereby certify that on August 6, 2007, the foregoing was snt to the following non-
registered participants in the manner indicated:
BY FEDERAL EXPRESS
Douglas I. Lewis John G. Hutchinson
Jamie L. Secord Sidley Austin, LLP
Sidiey Austin, LLP 787 Seventh Avenue
One South Dearborn Street New York, NY 10019
Chicago, IL 60603
Jaéson Al,. Tweedie (#4927)
[email protected]
RLFI-3186482-l