Free Declaration - District Court of Delaware - Delaware

Case 1 :08-cv—OO348-Gl\/IS Document 23 Filed 09/O3/2008 Page I ‘
[N THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
SAMSUNG ELECTRONICS CO., LTD. :
and LG ELECTRONICS CO., LTD., : .
Plaintiifs, : V
` _v. C.A. No. 08-348-GMS A
PETTERS GROUP WORLDWIDE, LLC, Judge Gregory M. Sleet
POLAROID CORPORATION, and : . ·
WESTINGHOUSE DIGITAL :
ELECTRONICS, LLC, :
Defendants. ·
DECLARATION OF DAVID BAER
Pursuant to 28 U.S.C. Section 1746, the undersigned declares, under penaltyof perjury,
. as follows; V
ll My name is David Baer, and am Chief Legal Officer of Petters Group _ _
Worldwide, LLC (“Petters"). I am a member of the Bar of the State of Minnesota, and I have
p served as Chief Legal Officer of Petters for approximately 5 years. My responsibilities include
overseeing substantially all of Petters’ legal operations. l make this declaration based on my
personal knowledge of matters, and based upon my review of pertinent tiles and/or infomation
provided to me by others upon whorn I rely. . `
. 2. Petters is a privately held, limited liability company organized under the laws of O
. the State of Delawme with its principal place of business at 4400 Baltermlioad, Minnetonka,
Minnesota 55343.
U 3. Petters is an investment company that is the parent of various companies around `
” the worlds including defendant Polaroid Corporation ("Polar0id”). Petters is a separate legal
entity from Polaroid. _ ‘
, . {2 ·

Case 1 :08-cv—OO348-GIVIS Document 23 Fil-ed 09/O3/2008 . Page 2 of 2 ·<·--— V
` 4. Petters does not make,_.use, sell, offer to sell, or import any of the following: e` p
. (i) televisions, including LCD televisions, DVD/television combinations, ‘
plasma televisions, and projection screen televisions;
‘ (ii) television tuners, including tuner cards; ’
(iii) set—top boxes capable of receiving terrestrial broadcast television; and I
4 (iv) video recorders with tuners, including DVD recorders and digital video
recorders (DVRs). V
p 5. Petters does not make, use, sell, offer to sell, or import products that are capable
of receiving digital ATSC television signals. · _
Executed this 3 day of September, 2008.
, V J ’ DavidBaer ¤ ° ' V

Case 1:08-cv-00348-GMS

Document 23

Filed 09/03/2008

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Case 1:08-cv-00348-GMS

Document 23

Filed 09/03/2008

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