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Case 2:23-cv-00059-JRG-RSP Document 361-4 Filed 02/28/25 Page 1 of 5 PageID
`#: 14792
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`(cid:6)(cid:19)(cid:8)(cid:9)(cid:3)(cid:9)(cid:16) (cid:4)
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`

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`Case 2:23-cv-00059-JRG-RSP Document 361-4 Filed 02/28/25 Page 2 of 5 PageID
`#: 14793
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`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`
`
`Plaintiff,
`
`
`
`v.
`
`
`TOUCHSTREAM TECHNOLOGIES, INC.,
`
`
`
`
`
`CHARTER COMMUNICATIONS, INC., et al.,
`
`Defendants.
`
`
`
`
`
`
` Lead Case No. 2:23-cv-00059-JRG
`
`
`
`Plaintiff,
`
`
`
`v.
`
`
`TOUCHSTREAM TECHNOLOGIES, INC.,
`
`
`
`
`
`COMCAST CABLE COMMUNICATIONS,
`LLC, D/B/A XFINITY, et al.,
`
`Defendants.
`
`
`
`
`
`Member Case No. 2:23-cv-00059-JRG
`
`
`
`JURY TRIAL DEMANDED
`
`CONTAINS HIGHLY CONFIDENTIAL
`– ATTORNEYS’ EYES ONLY
`INFORMATION
`
`EXPERT REPORT OF MICHAEL I. SHAMOS, PH.D.
`CONCERNING INVALIDITY
`
`
`
`
`
`
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`
`
`
`

`

`Case 2:23-cv-00059-JRG-RSP Document 361-4 Filed 02/28/25 Page 3 of 5 PageID
`#: 14794
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`

`

`Case 2:23-cv-00059-JRG-RSP Document 361-4 Filed 02/28/25 Page 4 of 5 PageID
`#: 14795
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`

`

`Case 2:23-cv-00059-JRG-RSP Document 361-4 Filed 02/28/25 Page 5 of 5 PageID
`#: 14796
`
`
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`779. Each Asserted Claim is entitled to a priority date no earlier than April 21, 2011, the
`
`filing date of Provisional Application No. 61/477,998.
`
`780. Each Asserted Claim lacks written description support.
`
`781. Each of the limitations of the Asserted Claims was well-known, routine and
`
`conventional as of the priority date.
`
`XVIII. TRIAL EXHIBITS
`
`782.
`
`I may rely on visual aids and demonstrative exhibits that demonstrate the bases of
`
`my opinions. Examples of these visual aids and demonstrative exhibits may include, for example,
`
`claim charts, patent drawings, excerpts from patent specifications, file histories, interrogatory
`
`responses, deposition testimony and deposition exhibits, as well as charts, diagrams, videos and
`
`animated or computer-generated video.
`
`XIX. SUPPLEMENTATION OF OPINIONS
`
`783.
`
`I reserve the right to adjust or supplement my opinions after I have had the
`
`opportunity to review further evidence or in light of additional documents that may be brought to
`
`my attention. I also reserve the right to adjust or supplement my analysis in response to any
`
`critique of or comments on my report or alternative opinions advanced by or on behalf of
`
`Plaintiff.
`
`
`
`Executed on June 24, 2024 at Vienna, Austria.
`
`
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`_________________________________
`Michael I. Shamos
`
`
`
`
`
`291
`
`

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