`
`
`SALIL BALI, State Bar No. 263001
` sbali@stradlinglaw.com
`STRADLING YOCCA CARLSON & RAUTH
`A PROFESSIONAL CORPORATION
`660 Newport Center Drive, Suite 1600
`Newport Beach, CA 92660-6422
`Telephone: 949 725 4000
`Facsimile: 949 725 4100
`
`ZIYONG SEAN LI, State Bar No. 289696
` sli@beneschlaw.com
`GREGORY CARL PROCTOR, State Bar No. 311214
` gproctor@beneschlaw.com
`BENESCH, FRIEDLANDER, COPLAN & ARONOFF LLP
`100 Pine Street, Suite 3100
`San Francisco, CA 94111
`Telephone:628.600.2250
`Facsimile: 628.221.5828
`
`KAL SHAH (admitted pro hac vice)
` kshah@beneschlaw.com
`BENESCH, FRIEDLANDER, COPLAN & ARONOFF LLP
`71 S. Wacker Drive, Suite 1600
`Chicago, IL 60606
`Telephone: 312-212-4949
`Facsimile: 312-767-9192
`
`Attorneys for Defendant
`Feit Electric Co., Inc.
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF CALIFORNIA
`WESTERN DIVISION
` CASE NO. 2:22-cv-05097
`SEOUL SEMICONDUCTOR CO.,
`
`LTD., a Korean corporation, SEOUL
`Honorable Andre Birotte Jr
`VIOSYS CO., LTD., a Korean
`Magistrate Shashi H. Kewalramani
`corporation,
`
`DECLARATION OF GREG
`PROCTOR IN SUPPORT OF JOINT
`STIPULATION RE: PLAINTIFFS’
`MOTION TO COMPEL DEFEDANT’S
`RESPONSES TO
`INTERROGATORIES 1-4, 7, 9, 11,
`AND 14
`
`Complaint Filed: July 7, 2022
`
`
`Plaintiff,
`vs.
`FEIT ELECTRIC CO., INC.,
`Defendant.
`
`
`
`
`DECLARATION OF G. PROCTOR IN SUPPORT OF JOINT STIPULATION RE: PLAINITIFFS’ MOTION TO COMPEL
`DEFENDANT’S RESPONSES TO INTERROGATORIES 1-4, 7, 9, 11, AND 14
`
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`
`
`Case 2:22-cv-05097-AB-SHK Document 79-3 Filed 05/05/23 Page 2 of 2 Page ID #:1591
`
`
`I, Greg Proctor, declare as follows:
`1.
`I am an attorney at law duly licensed to practice law in the State of
`California and admitted to the United States District Court for the Central District
`of California. I am an Attorney with the law firm Benesch, Friedlander, Coplan &
`Aronoff, LLP, counsel of record for Defendant Feit Electric Co., Inc. I make this
`declaration of my own personal knowledge, and if called as a witness in this
`action, I would and could testify completely to the matters stated herein.
`2.
`Attached hereto as Exhibit 29 is a true and correct copy of a court
`order dated September 22, 2022, in the case of CAO Lighting, Inc. v. Signify N.V.
`et al, docket no. 2:2:21-cv-08972 from the Central District of California.
`3.
` Attached hereto as Exhibit 30 is a true and correct copy of a court
`order dated November 21, 2019, in the case of Lexington Luminance LLC v. Feit
`Elec. Co., Inc., docket no. CV 18-10513-PSG from the Central District of
`California.
`4.
`Attached hereto as Exhibit 31 is a true and correct copy of Exhibit A-
`1 to SSC’s Preliminary Infringement Contentions, served on April 20, 2023.
`5.
`I declare under penalty of perjury under the laws of the State of
`California that the foregoing is true and correct. Executed this 26th day of April,
`2023, in Chicago, Illinois.
`
`
`
`/s/Greg Proctor
`Gregory C. Proctor
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`-1-
`DECLARATION OF G. PROCTOR IN SUPPORT OF JOINT STIPULATION RE: PLAINITIFFS’ MOTION TO COMPEL
`DEFENDANT’S RESPONSES TO INTERROGATORIES 1-4, 7, 9, 11, AND 14
`
`
`
`1 2 3 4 5 6 7 8 9
`
`10
`11
`12
`13
`14
`15
`16
`17
`18
`19
`20
`21
`22
`23
`24
`25
`26
`27
`28
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
