Free Declaration - District Court of Delaware - Delaware


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Date: March 3, 2006
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State: Delaware
Category: District Court of Delaware
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Case 1 :04-cv—OO876-GIVIS Document 93 Filed O3/O3/2006 Page 1 of 3
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
TELCORDIA TECHNOLOGIES, INC., )
Plaintiff/Counterclaim Defendant, g
v. g C. A. No. 04-876 (GMS)
CISCO SYSTEMS, INC., g
Defendant/Counterclaim Plaintiff g
DECLARATION OF LESLIE A. POLIZOTI IN SUPPORT
OF CISCO SYSTEMS, IN C.’S OPENING CLAIM CONSTRUCTION BRIEF
I, Leslie A. Polizoti, Esq., declare as follows:
1. I am a member of the Bar of this Court and an associate in the law firm of
Morris, Nichols, Arsht, & Turmell LLP, attorneys for defendant Cisco Systems, Inc. ("Cisco") in
this action. I make this declaration in support of Cisco Systems, Inc.’s Opening Claim
Construction Brief
2. Attached as Exhibit A is a true and correct copy of U.S. Patent No.
4,835,763, issued May 30, 1989.
3. Attached as Exhibit B is a true and correct copy of the original application
from the prosecution history for U.S. Patent No. 4,835,763, filed February 4, 1988.
4. Attached as Exhibit C is a true and correct copy of the office action from
the prosecution history for U.S. Patent No. 4,835,763, filed October 6, 1988.
5. Attached as Exhibit D is a true and correct copy of the amendment from
the prosecution history for U.S. Patent No. 4,835,763, filed January 10, 1989.
6. Attached as Exhibit E is a true and correct copy of excerpts from the IEEE
Standard Dictionary of Electrical and Electronics Terms (4th ed.), dated 1988.

Case 1:04-cv—OO876-G|\/IS Document 93 Filed O3/O3/2006 Page 2 of 3
7. Attached as Exhibit F is a true and correct copy of excerpts from the
Dictionary of Computers, Information Processing, and Telecommunications (2nd ed.), dated
1987.
8. Attached as Exhibit G is a true and correct copy of U.S. Patent No.
3,652,798, issued March 28, 1972.
9. Attached as Exhibit H is a true and correct copy of the court’s decision in
Curtiss- Wright F low Control Corp. v. Velan, Inc., 2006 WL 335609 (Fed. Cir. 2006), dated Feb.
15, 2006.
I declare under penalty of perjury that the fore oing is true and correct.
March 3, 2006
509579
2

Case 1:04-cv—OO876-G|\/IS Document 93 Filed O3/O3/2006 Page 3 of 3
CERTIFICATE OF SERVICE
I certify that on March 3, 2006 I electronically filed the foregoing
DECLARATION OF LESLIE A. POLIZOTI IN SUPPORT OF CISCO SYSTEMS,
INC.’S OPENING CLAIM CONSTRUCTION BRIEF with the Clerk of the Court using
CM/ECF, which will send notification of such filing to Steven J. Balick, Jack B. Blumenfeld,
John G. Day, Tiffany G. Lydon, Geoffrey Mason, Leslie A. Polizoti and John M. Williamson.
I fiuther certify that I caused to be served copies of the foregoing document on
March 3, 2006 upon the following in the manner indicated:
BY HAND BY FEDERAL EXPRESS
J ohn G. Day Don O. Burley
ASHBY & GEDDES FINNEGAN, HENDERSON, FARABOW,
222 Delaware Avenue GARETT & DUNNER
Wilmington, DE 19801 1300 I Street, N.W.
Washington, DC 20005-3315
BY ELECTRONIC MAIL
John Day (jday@ashby- geddes.com)
John Williamson ([email protected])
York Faulkner ([email protected])
Don Burley ([email protected])
/s/ Leslie A. Polizoti g#4299[
MORRIS, NICHOLS, ARSHT AND TUNNELL LLP
1201 North Market Street
Wilmington, DE 19801
(302) 658-9200