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The Facebook, Inc. v. Connectu, LLC et al - 100

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The Facebook, Inc. v. Connectu, LLC et al Doc. 100 Case 5:07-cv-01389-RS Document 100 Filed 07/06/2007 Page 1 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Scott R. Mosko (State Bar No. 106070) FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. Stanford Research Park 3300 Hillview Avenue Palo Alto, California 94304 Telephone: (650) 849-6600 Facsimile: (650) 849-6666 Attorneys for Defendants Pacific Northwest Software, Inc. and Winston Williams UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA SAN JOSE DIVISION FACEBOOK, INC., and MARK ZUCKERBERG, Plaintiffs, v. CONNECTU LLC, (now know as CONNECTU, INC.), CAMERON WINKLEVOSS, TYLER WINKLEVOSS, DIVYA NARENDRA, PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, WAYNE CHANG, DAVID GUCWA, and DOES 1-25, Defendants. CASE NO. C 07-01389 RS DECLARATION OF SCOTT R. MOSKO IN SUPPORT OF DEFENDANTS PACIFIC NORTHWEST SOFTWARE, INC.’S AND WINSTON WILLIAMS’S REPLY TO PLAINTIFFS’ OPPOSITION TO DEFENDANTS’ MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION Date: Time: Dept. Judge: July 11, 2007 9:30 a.m. 4 Hon. Richard Seeborg 20 21 22 23 24 25 26 27 28 Doc. No. 465473 DECLARATION OF SCOTT R. MOSKO CASE NO. 07 CV 01389 (RS) Dockets.Justia.com Case 5:07-cv-01389-RS Document 100 Filed 07/06/2007 Page 2 of 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 I, Scott R. Mosko declare, I am an attorney duly licensed to practice law in the state of California and am a member of Finnegan, Henderson, Farabow, Garrett & Dunner, LLP, attorneys of record for Defendant ConnectU LLC. If called to testify I would and could testify competently to the following matters. 1. Attached hereto as Exhibit A are true and correct copies of certain pages of testimony from the deposition of Winston Williams, taken in the pending action on June 19, 2007. (FILED UNDER SEAL) 2. Attached hereto as Exhibit B is a document entitled “Bylaws of TheFacebook, Inc.,” which comprises of Bates stamped pages FACE002103 - FACE002126. Exhibit B was served by the Defendants in response to a discovery request propounded in the Massachusetts action, Case No. 0411923DPW. (FILED UNDER SEAL) 3. Attached hereto as Exhibit C is a true and correct copy of Facebook, Inc.’s Answer to the First Amended Complaint in the District of Massachusetts action, filed October 28, 2004, Case No. 04-11923DPW. 4. Attached hereto as Exhibit D is a true and correct copy of Facebook, Inc.’s Supplemental Responses to ConnectU, LLC’s First Set of Interrogatories Nos. 9-14, 18 in the District of Massachusetts action, served May 1, 2006, Case No. 04-11923DPW. (FILED UNDER SEAL) I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct and that this declaration was executed on the 6th day of July 2007. /s/ Scott R. Mosko Doc. No. 465473 1 DECLARATION OF SCOTT R. MOSKO CASE NO. 07 CV 01389 (RS)
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