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`FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER
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`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`TOUCHSTREAM TECHNOLOGIES, INC.,
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`Plaintiff,
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`v.
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`CHARTER COMMUNICATIONS, INC., et al.,
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`Defendants.
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`TOUCHSTREAM TECHNOLOGIES, INC.,
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`Plaintiff,
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`v.
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`COMCAST CABLE COMMUNICATIONS,
`LLC, D/B/A XFINITY, et al.,
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`Defendants.
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`Lead Case No. 2:23-cv-00059-JRG
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`CONTAINS RESTRICTED
`CONFIDENTIAL – ATTORNEYS’
`EYES ONLY INFORMATION
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`Member Case No. 2:23-cv-00062-JRG
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`DECLARATION OF CHRISTOPHER BAKEWELL
`IN SUPPORT OF CHARTER’S NOTICE OF TRIAL CONFLICT
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`Case 2:23-cv-00059-JRG-RSP Document 313-1 Filed 02/07/25 Page 2 of 2 PageID
`#: 14068
`FILED UNDER SEAL PURSUANT TO PROTECTIVE ORDER
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`I, Christopher Bakewell, declare:
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`1.
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`I am a Vice President and officer of Charles River Associates, where I provide consulting
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`services involving valuation, licensing and related issues in connection with technology-rich
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`business and intellectual property.
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`2.
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`I was retained by the Charter Defendants (“Charter”) in this matter as a damages expert
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`and provided an expert report which includes opinions on each of the Georgia-Pacific factors
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`related to a hypothetical negotiation, the date of the hypothetical negotiation, lump sum versus a
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`running royalty, apportionment and the application to method claims. My expert report is the result
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`of extensive review of the discovery record in this matter and I was deposed with respect to the
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`opinions contained in my report.
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`3.
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`I understand that I will testify at trial in this matter as Charter’s damages expert witness on
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`the opinions contained in my report.
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`4.
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`I have also been retained as an economic expert in the case Fundamental Innovation
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`Systems International LLC v. Anker Innovations Ltd., No. 1:21-cv-00339-RGA, (D. Del.) on behalf
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`of the Defendant, Anker Innovations Ltd. There is a week-long trial scheduled in the District Court
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`of Delaware from March 3rd and through March 7th.
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`I declare under penalty of perjury that the above is true and correct.
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`Dated: February 6, 2025
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`Respectfully submitted,
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`Christopher Bakewell
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`2
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