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`
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`
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`
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` Civil Action No. 6:22-cv-31-ADA
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` JURY TRIAL DEMANDED
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`FLYPSI, INC. (D/B/A FLYP),
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` Plaintiff,
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` vs.
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`GOOGLE LLC,
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` Defendant.
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`
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`PLAINTIFF FLYPSI, INC.’S NOTICE OF SUPPLEMENTAL
`CLAIM CONSTRUCTION EVIDENCE
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`In support of its Motion to Transfer (Dkt. No. 42), Google submitted the Declaration of
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` (Dkt. No. 42-2). Mr.
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`’s declaration stated that he “
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`
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`
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`” (Id. at ¶ 2 (emphasis
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`added)).
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`On October 6, 2022, Flyp deposed Mr.
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` related to his declaration and other venue-
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`related topics. Excerpts of that deposition are attached as Exhibit A. During that deposition, Flyp
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`explored Mr.
`
`’s understanding of subparagraph (i) of the above defined focus. Mr.
`
`—
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`a Google engineer and Product Manager for Google Voice—had a clear understanding of the terms
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`“primary number” and “secondary number” further supporting Flyp’s position that the terms
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`“primary telephone number” and “secondary telephone number” are not indefinite to persons of
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`ordinary skill in the art. (Ex. A at 63:23-64:3 and 65:12-66:20).
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`1
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`Case 6:22-cv-00031-ADA Document 61 Filed 10/19/22 Page 2 of 3
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`FILED UNDER SEAL
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`DATED: October 12, 2022
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`Respectfully submitted,
`
`/s/ Michael A. Bittner
`Thomas M. Melsheimer
`Texas Bar No. 13922550
`tmelsheimer@winston.com
`M. Brett Johnson
`Texas Bar No. 00790975
`mbjohnson@winston.com
`Michael A. Bittner
`Texas Bar No. 24064905
`mbittner@winston.com
`Steven R. Laxton
`Texas Bar No. 24120639
`slaxton@winston.com
`WINSTON & STRAWN LLP
`2121 North Pearl Street, Suite 900
`Dallas, TX 75201
`Telephone: (214) 453-6500
`
`Matthew R. McCullough
`California Bar No. 301330
`mrmccullough@winston.com
`WINSTON & STRAWN LLP
`275 Middlefield Road, Suite 205
`Menlo Park, CA 94025
`Telephone: (650) 858-6500
`
`William M. Logan
`Texas Bar No. 24106214
`wlogan@winston.com
`WINSTON & STRAWN LLP
`800 Capitol Street, Suite 2400
`Houston, TX 77002
`Telephone: (713) 651-2766
`
`ATTORNEYS FOR PLAINTIFF
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`2
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`Case 6:22-cv-00031-ADA Document 61 Filed 10/19/22 Page 3 of 3
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`FILED UNDER SEAL
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`CERTIFICATE OF SERVICE
`
`I hereby certify that a copy of the foregoing document was filed electronically in
`compliance with Local Rule CV-5. Therefore, this document was served on all counsel who are
`deemed to have consented to electronic service. Administrative Policies and Procedures for
`Electronic Filing in Civil and Criminal Cases, Western District of Texas, Section 14.
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`/s/ Michael A. Bittner
`Michael A. Bittner
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`3
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