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`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
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`VLSI TECHNOLOGY LLC,
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`Plaintiff,
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`v.
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`INTEL CORPORATION,
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`Defendant.
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`Civil Action No. 18-966-CFC-CJB
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`FILED UNDER SEAL
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`DECLARATION OF BRIAN E. FARNAN
`IN SUPPORT OF VLSI TECHNOLOGY LLC’S RESPONSE TO
` INTEL CORPORATION’S OBJECTION TO VLSI’S RESPONSE TO
`THE COURT’S AUGUST 1, 2022 ORDER
`I, Brian E. Farnan, declare:
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`1.
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`I am a member of the bar of the State of Delaware and a partner at
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`Farnan LLP, counsel of record for Plaintiff in this action. I respectfully submit this
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`Declaration and accompanying documents in support of VLSI Technology LLC’s
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`Response to Intel Corporation’s Objection to VLSI’s Response to the Court’s
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`August 1, 2022 Order.
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`1.
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`Attached hereto as Exhibit A is a true and correct copy of excerpts from
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`the deposition of Michael Stolarski, Esquire dated Thursday, July 9, 2020.
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`
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`Case 1:18-cv-00966-CFC-CJB Document 987 Filed 09/06/22 Page 2 of 2 PageID #: 38089
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`2.
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`Attached hereto as Exhibit B is a true and correct copy of excerpts from
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`the deposition of Michael Stolarski, Esquire dated Thursday, October 17, 2019.
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`3.
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`Attached hereto as Exhibit C is a true and correct copy of excerpts from
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`the deposition of Jonathan M. James dated Thursday, November 18, 2021.
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`4.
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`Attached hereto as Exhibit D is a true and correct copy of a letter from
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`Kathryn G. Cole, Esquire to Rachel Bier, Esquire dated October 29, 2021 and
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`marked as Exhibit James 1.
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`5.
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`Attached hereto as Exhibit E is a true and correct copy of excerpts from
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`the Permanent University Fund Detail Schedules of Investment Securities and
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`Independent Auditors’ Report for the University of Texas/Texas A&M Investment
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`Management Company dated August 31, 2012.
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`6.
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` Attached hereto as Exhibit F is a true and correct copy of excerpts from
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`the Permanent University Fund Detail Schedules of Investment Securities and
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`Independent Auditors' Report for the University of Texas/Texas A&M Investment
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`Management Company dated August 31, 2020.
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`I declare under penalty of perjury under the laws of the United States of
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`America that the following is true and correct
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`Dated: August 30, 2022
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`
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`
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`/s/ Brian E. Farnan
`Brian E. Farnan (Bar No. 4089)
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`2
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