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MEHTA DECL. ISO DEFENDANT FACEBOOK, INC.’S OPPOSITION TO PLAINTIFF SIX4THREE, 

LLC’S MOTION TO REMAND / CASE NO. 3:17-CV-00359-WHA

DURIE TANGRI LLP

SONAL N. MEHTA (SBN 222086)

smehta@durietangri.com

LAURA E. MILLER (SBN 271713)

lmiller@durietangri.com

CATHERINE Y. KIM (SBN 308442)

ckim@durietangri.com

217 Leidesdorff Street

San Francisco, CA 94111

Telephone: 415-362-6666

Facsimile: 415-236-6300

Attorneys for Defendant 

Facebook, Inc.

IN THE UNITED STATES DISTRICT COURT

FOR THE NORTHERN DISTRICT OF CALIFORNIA

SAN FRANCISCO DIVISION

SIX4THREE, LLC, 

Plaintiff,

v.

FACEBOOK, INC.,

Defendant.

Case No. 3:17-cv-00359-WHA

DECLARATION OF SONAL N. MEHTA IN 

SUPPORT OF DEFENDANT FACEBOOK, 

INC.’S OPPOSITION TO PLAINTIFF 

SIX4THREE, LLC’S MOTION TO REMAND

Date: February 16, 2017

Time: 8:00 a.m.

Ctrm: 8, 19th Floor

Judge: Honorable William Alsup

Case 3:17-cv-00359-WHA Document 20-1 Filed 02/06/17 Page 1 of 3
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1

MEHTA DECL. ISO DEFENDANT FACEBOOK, INC.’S OPPOSITION TO PLAINTIFF SIX4THREE, 

LLC’S MOTION TO REMAND / CASE NO. 3:17-CV-00359-WHA

I, Sonal N. Mehta, declare as follows:

1. I am an attorney with the law firm Durie Tangri LLP, counsel for Defendant Facebook, 

Inc. (“Facebook”) in the above-captioned matter. I have personal knowledge of the facts set forth herein, 

and if called upon to testify, I could and would testify to the statements made herein.

2. Attached hereto as Exhibit 1 is a true and correct copy of excerpts from Plaintiff 

Six4Three, LLC’s Verified Third Supplemental Response to Defendant Facebook, Inc.’s Special

Interrogatories, served on December 27, 2016.

3. Attached hereto as Exhibit 2 is a true and correct copy of the Complaint for Declaratory 

Judgment and Injunctive Relief of Plaintiff, Six4Three, LLC, Case No. 3:16-cv-06716-JCS (N.D. Cal.), 

filed on November 21, 2016.

4. Attached hereto as Exhibit 3 is a true and correct copy of email correspondence from 

Facebook’s Counsel to Six4Three, LLC’s Counsel, dated January 20, 2017. Six4Three did not respond 

to this email.

5. In litigating this case in state court, Facebook filed demurrers to Six4Three’s original 

complaint, First Amended Complaint, and Second Amended Complaint; engaged in written discovery 

and document production, including producing more than 800,000 pages of documents; took the 

depositions of two Six4Three witnesses; and was prepared to move for summary judgment.

I declare under the penalty of perjury that the foregoing is true and correct. Executed on February 

6, 2017 in San Francisco, California.

/s/ Sonal. N. Mehta

SONAL N. MEHTA

Case 3:17-cv-00359-WHA Document 20-1 Filed 02/06/17 Page 2 of 3
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MEHTA DECL. ISO DEFENDANT FACEBOOK, INC.’S OPPOSITION TO PLAINTIFF SIX4THREE, 

LLC’S MOTION TO REMAND / CASE NO. 3:17-CV-00359-WHA

CERTIFICATE OF SERVICE

I hereby certify that on February 6, 2017 the within document was filed with the Clerk of the 

Court using CM/ECF which will send notification of such filing to the attorneys of record in this case.

/s/ Sonal N. Mehta

SONAL N. MEHTA

Case 3:17-cv-00359-WHA Document 20-1 Filed 02/06/17 Page 3 of 3