`#: 14069
`
`Filed 02/07/25
`
`Page 1 of 2 PagelD
`
`UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`TOUCHSTREAM TECHNOLOGIES,INC.,
`
`Plaintiff,
`
`Vv.
`
`CHARTER COMMUNICATIONS,INC.,et al.,
`
`Defendants.
`
`
`
`TOUCHSTREAM TECHNOLOGIES,INC.,
`
`Plaintiff.
`
`Me
`
`COMCAST CABLE COMMUNICATIONS,
`LLC, D/B/A XFINITY,et al.,
`
`Defendants.
`
`
`
`Lead Case No. 2:23-cv-00059-JRG
`
`CONTAINS RESTRICTED
`CONFIDENTIAL -— ATTORNEYS’
`EYES ONLY INFORMATION
`
`Member Case No. 2:23-cv-00062-JRG
`
`DECLARATION OF DAVID G. BELL
`IN SUPPORT OF CHARTER’S NOTICE OF TRIAL CONFLICT
`
`
`
`Case 2:23-cv-00059-JRG-RSP Document 313-2
`#: 14070
`
`Filed 02/07/25
`
`Page 2 of 2 PagelD
`
`I, David G. Bell, declare:
`
`1.
`
`I am a former employee ofseveral subsidiaries of Charter Communications, Inc. and
`
`current Vice President of Software at Prime Robotics.
`
`2.
`
`3
`
`In 2002, I began working as a Software Developer at Time Warner Cable,Inc.
`
`I was promoted to Chief Architect, then Technical Fellow and responsible for designing
`
`software and supervising teams to write code to offer cable TV services. In 2009, I was a Chief
`
`Architect in the engineering team at Time Warner Cable supporting the developmentof the app
`
`and supporting infrastructure that matured into the app which I understand is the basis of
`
`Touchstream Technologies, Inc.’s infringement allegation.
`
`I remained at Time Warner Cable
`
`whenit became part of Charter in 2016.
`
`4.
`
`I understand that Charter expects metotestify at trial in this matter as a fact witness to
`
`explain developmentand functionality of the app and its accused Send To TV feature.
`
`5;
`
`I am not available for trial between March 13 and March 20, 2025 because I will be in
`
`Ireland with my wife chaperoning over 100 students, including my son, from the Legacy High
`
`School Lightning Band. The students have been invited to march in the 2025 St. Patrick’s Day
`
`Parade in Dublin. The trip has been planned since February 22, 2023.
`
`I declare under penalty of perjury that the aboveis true and correct.
`
`Dated: February 6, 2025
`
`Respectfully submitted,
`
`David G. Bell
`Broomfield, Colorado
`
`
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