`#: 14121
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`TOUCHSTREAM TECHNOLOGIES, INC.,
`Plaintiff,
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`v.
`CHARTER COMMUNICATIONS, INC., et
`al.,
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`Defendants.
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`TOUCHSTREAM TECHNOLOGIES, INC.,
`Plaintiff,
`
`v.
`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
`Member Case No. 2:23-cv-00062-JRG
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`DECLARATION OF KEON ZEMOUDEH IN SUPPORT OF
`COMCAST’S OBJECTION TO THE MAGISTRATE JUDGE’S DECISION
`OVERRULING COMCAST’S OBJECTIONS TO PLAINTIFF’S TRIAL EXHIBIT 7
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`I, Keon Zemoudeh, declare as follows pursuant to 28 U.S.C. § 1746:
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`I am an attorney admitted to practice before this Court and an attorney at Davis Polk &
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`Wardwell LLP, counsel in the above-captioned matter for Defendants Comcast Cable
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`Communications, LLC, Comcast Corporation, Comcast Cable Communications Management,
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`LLC, and Comcast of Houston, LLC (collectively, “Comcast”). I submit this declaration in
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`support of Comcast’s Objection to the Magistrate Judge’s Decision Overruling Comcast’s
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`Objections to Plaintiff’s Trial Exhibit 7 (the “Objection”).
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`I have attached to this declaration exhibits on which Comcast relies in support of the
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`Objection. Pursuant to Local Rule CV-7(b), I have excerpted and highlighted the cited-to
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`portions of the underlying materials in preparing these exhibits.
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`Case 2:23-cv-00059-JRG-RSP Document 320-2 Filed 02/11/25 Page 2 of 2 PageID
`#: 14122
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`1.
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`Attached hereto as Exhibit 1 is a true and correct excerpt of the transcript of the
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`pretrial conference held in the above-captioned matter on January 23, 2025.
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`2.
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`Attached hereto as Exhibit 2 is a true and correct excerpt of the Patent License
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`Agreement between
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`3.
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`Attached hereto as Exhibit 3 is a true and correct copy of the webpage entitled,
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`.
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`4.
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`Attached hereto as Exhibit 4 is a true and correct excerpt of
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`5.
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`Attached hereto as Exhibit 5 is a true and correct excerpt of
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`.
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`6.
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`Attached hereto as Exhibit 6 is a true and correct excerpt of
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`7.
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`Attached hereto as Exhibit 7 is a true and correct copy of the webpage entitled,
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`8.
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`Attached hereto as Exhibit 8 is a true and correct copy of the webpage entitled,
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`I declare under penalty of perjury that the foregoing is true and correct.
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`.
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`Executed on: February 6, 2025
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` Marshall, Texas
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`/s/ Keon Zemoudeh
`Keon Zemoudeh
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`2
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