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`Plaintiff,
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF ILLINOIS
`EASTERN DIVISION
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`Civil Action No.: 1:16-cv-06097
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`Judge Harry D. Leinenweber
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`Magistrate Judge Sidney Schenkier
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`Jury Trial Demanded
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`THE CHAMBERLAIN GROUP, INC.,
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`
`v.
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`TECHTRONIC INDUSTRIES CO. LTD.,
`TECHTRONIC INDUSTRIES NORTH AMERICA,
`INC., ONE WORLD TECHNOLOGIES INC.,
`OWT INDUSTRIES, INC., ET TECHNOLOGY
`(WUXI) CO. LTD., AND RYOBI
`TECHNOLOGIES, INC.
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`
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`Defendants.
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`DECLARATION OF MARIA ELENA STITELER IN SUPPORT OF PLAINTIFF’S
`MOTION FOR PERMANENT INJUNCTION
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`I, Maria Elena Stiteler, declare as follows:
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`1.
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`I am an attorney at the law firm of Fish & Richardson P.C., counsel of record in
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`this action for Plaintiff The Chamberlain Group, Inc. (“CGI”). I am a member of the Bar of the
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`States of California and Minnesota and have been admitted Pro Hac Vice in this case. I have
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`personal knowledge of the matters stated in this declaration and would testify truthfully to them
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`if called upon to do so.
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`2.
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`I submit this declaration in support of Plaintiff’s Motion for a Permanent
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`Injunction.
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`3.
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`4.
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`Attached as Exhibit A is CGI’s proposed injunction order.
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`Attached as Exhibit B are excerpts from the transcript from day two of the trial
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`proceedings on August 22, 2017.
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`
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`Case: 1:16-cv-06097 Document #: 622-1 Filed: 09/27/17 Page 2 of 4 PageID #:23565
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`5.
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`Attached as Exhibit C are excerpts from the transcript from day three of the trial
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`proceedings on August 23, 2017.
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`6.
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`7.
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`Attached as Exhibit D is Plaintiff’s Exhibit 406.
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`Attached as Exhibit E are excerpts from the transcript from day seven of the trial
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`proceedings on August 29, 2017.
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`8.
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`9.
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`Attached as Exhibit F is Plaintiff’s Exhibit 548.
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`Attached as Exhibit G are excerpts from Plaintiff’s Exhibit 167.
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`10.
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`Attached as Exhibit H are excerpts from the transcript from day four of the trial
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`proceedings on August 24, 2017.
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`11.
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`Attached as Exhibit I are excerpts from Defendant’s Exhibit 255.
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`12.
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`Attached as Exhibit J is Plaintiff’s Exhibit 237.
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`13.
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`Attached as Exhibit K are excerpts from the transcript from day one of the trial
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`proceedings on August 21, 2017.
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`14.
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`Attached as Exhibit L is Plaintiff’s Exhibit 306.
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`15.
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`Attached as Exhibit M are excerpts from Plaintiff’s Exhibit 168.
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`16.
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`Attached as Exhibit N is Plaintiff’s Exhibit 350.
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`17.
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`Attached as Exhibit O is Plaintiff’s Exhibit 632.
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`18.
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`Attached as Exhibit P is Plaintiff’s Exhibit 392.
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`19.
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`Attached as Exhibit Q is Plaintiff’s Exhibit 400.
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`20.
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`Attached as Exhibit R are excerpts of an excel spreadsheet, produced by TTI with
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`the bates number TTI00010632, showing TTI’s sales of Ryobi GDOs to Home Depot on
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`September 17, 2016.
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`
`
`2
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`
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`Case: 1:16-cv-06097 Document #: 622-1 Filed: 09/27/17 Page 3 of 4 PageID #:23566
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`21.
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`Attached as Exhibit S are excerpts from the transcript from the deposition of
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`Kevin Cameron, taken on Tuesday, December 6, 2016.
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`22.
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`Attached as Exhibit T are excerpts from the transcript from the deposition of
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`Mark Huggins, taken on March 24, 2017.
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`23.
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`Attached as Exhibit U are excerpts from the transcript from the deposition of
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`William McNabb, taken on January 9, 2017.
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`24.
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`Attached as Exhibit V are true and correct printouts of the webpages for TTI’s
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`Ryobi GD125 and GD200A, captured on September 14, 2017, from
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`https://www.ryobitools.com/power-tools/products/list/category/garage-door-opener.
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`25.
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`Attached as Exhibit W is a true and correct printout of the webpage to download
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`the phone application that supports both TTI’s Ryobi GD125 and GD200A, captured on
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`September 26, 2017, from https://itunes.apple.com/us/app/gdo-system/id1097529087?mt=8.
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`26.
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`Attached as Exhibit X are excerpts of the owner’s manuals for TTI’s Ryobi
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`GD125 and GD200A GDOs.
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`27.
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`Attached as Exhibit Y is a true and correct copy of a spreadsheet, produced by
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`TTI on September 25, 2017, with updated sales figures of TTI’s GDOs and accessories,
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`including the Ryobi GD125. Sales of the Ryobi GD125 in August, 2017, are recorded in cell
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`DG-6.
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`I declare under penalty of perjury under the laws of the United States that the foregoing is
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`true and correct. Executed at Minneapolis, Minnesota, this 27th day of September, 2017.
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`3
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`
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`Case: 1:16-cv-06097 Document #: 622-1 Filed: 09/27/17 Page 4 of 4 PageID #:23567
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`Dated: September 27, 2017
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`FISH & RICHARDSON P.C.
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`
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`
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`By: /s/ Maria Elena Stiteler
` Maria Elena Stiteler
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`4
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