Arista Records LLC et al v. Lime Wire LLC et al

Filing 282

DECLARATION of Sunil Sreenivasan in Opposition re: 242 MOTION for Preliminary Injunction Freezing Defendants' Assets.. Document filed by M.J.G. Lime Wire Family Limited Partnership, Lime Wire LLC, Lime Group LLC, Mark Gorton. (Klausner, Tonia Maria)

Arista Records LLC et al v. Lime Wire LLC et al Doc. 282 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK ARIST A RECORDS LLC; ATLANTIC RECORDING CORPORATION; BMG MUSIC; CAPITOL RECORDS, INC.; ELEKTRA ENTERTAINMENT GROUP INC.; INTERS COPE RECORDS; LAFACE RECORDS LLC; MOTOWN) RECORD COMPANY, L.P.; PRIORITY RECORDS LLC; SONY BMG MUSIC ENTERTAINMENT; UMG RECORDINGS, INC.; VIRGIN RECORDS AMERICA, INC.; and WARNER BROS. RECORDS INC., Plaintiffs, v. LIME WIRE LLC; LIME GROUP LLC; MARK GORTON; GREG BILDSON; and MJ.G. LIME WIRE FAMILY LIMITED PARTNERSHIP, Defendants. ) ) ) ) ) Case No. 06 CV 5936 (KMW) ECF Case DECLARATION OF SUNIL SREENIVASAN ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) ) J, Sunil Sreenivasan, the undersigned, hereby declare: 1. I am over twenty-one (21) years of age and am of sound mind. I have personal knowledge of the facts stated herein, I am competent to testify thereto, and if called to testify, I could and would testify to the following. 2. I am the Chief Technology Officer of Lime Medical LLC, a Delaware Limited Liability Company incorporated in August 2006 and based in New York, New York. Lime Medical has a full-time staff of two employees, with a third joining next week. We maintain a website at www.limemedical.com. 3. Lime Medical is a health technology company whose goal is to provide leading edge technology and design to software for health care providers. We develop intuitive and easy to use software tools for clinical providers. These tools help improve patient care and safety, increase efficiency of provider work processesat the point of care and increase financial returns for hospitals and private practices. Lime Medical is an early stage startup focused on developing -1- Dockets.Justia.com innovative software solutions for physicians and other clinical care providers. We aim to make our software as easy to use as writing on paper. 4. One example of our work is our first products in the iPatient umbrella, which include tools for charge capture and patient handoff. The charge capture product helps physicians quickly and easily record codified diagnostic and charge information at close to real time. This information helps the provider organization easily obtain payment from insurance payers. The handoff product helps hospital-based physicians efficiently record patient care information for effectively handing off the patient to the next member of their teams. 5. Mark Gorton is the co-founder of Lime Medical. 100% of Lime Medical's funding comes directly or indirectly from Mark Gorton. If he were no longer able to fund Lime Medical, it would ceaseto exist. I HEREBY DECLARE and certify under penalty of perjury under the laws of the United States of America that the foregoing is true and correct, and that this Declaration was executed this ~day of June 2010 in New York, New York. -2-