UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

DROPBOX, INC.,

Plaintiff/Counter-Defendant,

v.

MOTION OFFENSE, LLC, 

Defendant/Counter-Plaintiff.

CIVIL ACTION NO. 6:20-cv-00251-ADA

MOTION OFFENSE, LLC 

Plaintiff,

v.

DROPBOX, INC., 

Defendant.

CIVIL ACTION NO. 6:21-cv-00758-ADA

DECLARATION OF SRIKANT CHERUVU IN SUPPORT OF 

MOTION OFFENSE, LLC’S OPPOSITION TO DROPBOX, INC.’S MOTION 

TO STRIKE AMENDED INFRINGEMENT CONTENTIONS

Dated: July 20, 2022 Timothy Devlin (No. 4241)

DEVLIN LAW FIRM LLC

1526 Gilpin Avenue 

Wilmington, DE 19806

Telephone: (302) 449-9010

tdevlin@devlinlawfirm.com

Attorneys for Plaintiff 

Motion Offense, LLC

Case 6:20-cv-00251-ADA Document 156 Filed 07/20/22 Page 1 of 4
I, Srikant Cheruvu, hereby declare:

1. I am an attorney admitted to practice in New York, and have been admitted pro 

hac vice in this action. I am an attorney at the Devlin Law Firm LLC, counsel for Motion 

Offense LLC (“Motion Offense”) in the above-captioned actions. I provide this declaration in 

support of Motion Offense, LLC’s Opposition to Dropbox Inc.’s Motion to Strike Motion 

Offense LLC’s July 1 Amended Infringement Contentions.

2. Unless otherwise indicated below, the statements in this declaration are based on 

my personal knowledge and my review of the documents cited herein. If called to testify as a 

witness, I could and would competently do so under oath.

3. Attached as Exhibit 1 is a comparison of exemplary folder sharing limitations of 

U.S. Patent No. 10,013,158 (the “’158 patent”) with exemplary folder sharing limitations of U.S. 

Patent No. 11,044,215 (the “’215 patent”). 

4. Attached as Exhibit 2 is a comparison of exemplary file request limitations of 

U.S. Patent No. 10,021,052 (the “’052 patent”) with exemplary file request limitations of the 

’215 patent. 

5. Attached as Exhibit 3 are excerpts from the June 29, 2022 deposition of Maxime 

Larabie-Belanger. 

6. Attached as Exhibit 4 are excerpts from the June 30, 2022 deposition of Deborah 

Holstein.

7. Attached as Exhibit 5 is a true and correct copy of a document Bates-numbered 

DRBX_MoOff_000062775. 

8. Attached as Exhibit 6 is a true and correct copy of a document Bates-numbered 

DRBX_MoOff_000025446. 

Case 6:20-cv-00251-ADA Document 156 Filed 07/20/22 Page 2 of 4
9. Attached as Exhibit 7 are excerpts from Motion Offense’s October 15, 2021 and 

July 1, 2022 infringement contentions for the ’158 and ’215 patents showing exemplary steps for 

team folder sharing and personal folder sharing with Dropbox. 

10. Attached as Exhibit 8 is a true and correct copy of a document Bates-numbered 

DRBX_MoOff_000059559. 

11. Attached as Exhibit 9 is a true and correct copy of a document Bates-numbered 

DRBX_MoOff_000036453. 

12. Attached as Exhibit 10 is a true and correct copy of a document Bates-numbered 

MOTIONOFFENSE0002417. 

13. Attached as Exhibit 11 are excerpts from Motion Offense’s October 15, 2021 and 

July 1, 2022 infringement contentions for the ’215 patent, showing the operation of the Dropbox 

desktop application. 

14. Attached as Exhibit 12 is a true and correct copy of an email thread between L. 

Herriot and S. Cheruvu on or around April 19, 2021. 

15. Attached as Exhibit 13 are excerpts from Dropbox’s Sixth Supplemental 

Objections and Responses to Motion Offense, LLC’s First Set of Interrogatories (Nos. 1-10), 

dated July 1, 2022. 

16. Attached as Exhibit 14 is a true and correct copy of a document Bates-numbered 

DRBX_MoOff_000059757. 

17. Attached as Exhibit 15 are excerpts from the June 10, 2022 deposition of Sarah 

Schubach. 

18. Attached as Exhibit 16 is a true and correct copy of Exhibit 32 to the June 29, 

2022 deposition of Maxime Larabie-Belanger. 

Case 6:20-cv-00251-ADA Document 156 Filed 07/20/22 Page 3 of 4
19. Attached as Exhibit 17 is a true and correct copy of a document Bates-numbered 

DRBX_MoOff_000051676-87. 

I declare under penalty of perjury under the laws of the United States that the foregoing is 

true and correct.

Executed on July 20, 2022. 

Srikant Cheruvu 

Case 6:20-cv-00251-ADA Document 156 Filed 07/20/22 Page 4 of 4