`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`FLYPSI, INC., (D/B/A FLYP),
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`
`
`CIVIL ACTION NO. 6:22-cv-00031-ADA
`
`JURY TRIAL DEMANDED
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`DECLARATION OF JOHN COTIGUALA IN SUPPORT OF DEFENDANT GOOGLE
`LLC’S OPPOSED MOTION TO STAY PENDING INTER PARTES REVIEW
`
`I, John Cotiguala, declare and state as follows:
`
`1.
`
`I am an attorney with the law firm Paul Hastings LLP and counsel for Defendant
`
`Google LLC (“Google”). I have personal knowledge of the facts contained in this declaration and,
`
`if called upon to do so, I could and would testify competently to the matters set forth herein.
`
`2.
`
`3.
`
`4.
`
`5.
`
`6.
`
`7.
`
`Claims 1-6 of U.S. Patent No. 9,667,770 are asserted in this case.
`
`Claims 1-11 of U.S. Patent No. 10,051,105 are asserted in this case.
`
`Claims 1-4 of U.S. Patent No. 10,334,094 are asserted in this case.
`
`Claims 1-4 of U.S. Patent No. 11,012,554 are asserted in this case.
`
`Claims 1-4 of U.S. Patent No. 11,218,585 are asserted in this case.
`
`Attached hereto as Exhibit 1 is a true and correct copy of the decision granting
`
`institution of inter partes review in IPR2023-00360.
`
`8.
`
`Attached hereto as Exhibit 2 is a true and correct copy of the decision granting
`
`institution of inter partes review in IPR2023-00361.
`
`
`
`Case 6:22-cv-00031-ADA Document 127-1 Filed 08/18/23 Page 2 of 2
`
`9.
`
`Attached hereto as Exhibit 3 is a true and correct copy of the decision granting
`
`institution of inter partes review in IPR2023-00358.
`
`10.
`
`Attached hereto as Exhibit 4 is a true and correct copy of the decision granting
`
`institution of inter partes review in IPR2023-00359.
`
`11.
`
`Attached hereto as Exhibit 5 is a true and correct copy of the decision granting
`
`institution of inter partes review in IPR2023-00357.
`
`I declare under penalty of perjury that to the best of my knowledge the foregoing is true
`
`and correct. Executed this 18th day of August, 2023, in Chicago, Illinois.
`
`
`
`/s/ John Cotiguala
`John Cotiguala
`
`
`
`-2-
`
`
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