Sony Computer Entertainment America LLC v. Hotz et al

Filing 105

DECLARATION in Support of 103 Opposition/Response to Motion filed bySony Computer Entertainment America LLC. (Attachments: # 1 Affidavit Liu Declaration, # 2 Affidavit Pierce, # 3 Proposed Order)(Related document(s) 103 ) (Smith, Mehrnaz) (Filed on 3/19/2011) Modified on 3/21/2011 (ys, COURT STAFF).

Sony Computer Entertainment America LLC v. Hotz et al

Doc. 105 Att. 1

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KILPATRICK TOWNSEND & STOCKTON LLP JAMES G. GILLILAND, JR. (State Bar No. 107988) TIMOTHY R. CAHN (State Bar No. 162136) MEHRNAZ BOROUMAND SMITH (State Bar No. 197271) HOLLY GAUDREAU (State Bar No. 209114) RYAN BRICKER (State Bar No. 269100) Two Embarcadero Center Eighth Floor San Francisco, CA 94111 Telephone: [phone] Facsimile: [phone] Email: [e-mail] [e-mail] [e-mail] [e-mail] [e-mail] Attorneys for Plaintiff SONY COMPUTER ENTERTAINMENT AMERICA LLC UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA SAN FRANCISCO DIVISION SONY COMPUTER ENTERTAINMENT AMERICA LLC, Plaintiff, v. GEORGE HOTZ; HECTOR MARTIN CANTERO; SVEN PETER; and DOES 1 through 100, Defendants. Case No. 11-cv-00167 SI DECLARATION OF JENNIFER LIU IN SUPPORT OF PLAINTIFF SONY COMPUTER ENTERTAINMENT AMERICA LLC'S OPPOSITION TO DEFENDANT GEORGE HOTZ'S MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION AND IMPROPER VENUE Date: Time: Courtroom: Judge: April 8, 2011 9:00 a.m. 10, 19th Floor Hon. Susan Illston

I, Jennifer Liu, declare as follows: 1. I am an employee of Sony Computer Entertainment America LLC ("SCEA"), and

work at SCEA's headquarters in Foster City, California. My title at SCEA is Vice President and Deputy General Counsel of Business and Legal Affairs. I make this declaration on personal knowledge and if called as a witness could and would testify competently thereto.

DECLARATION OF JENNIFER LIU IN SUPPORT OF PLAINTIFF SONY COMPUTER ENTERTAINMENT AMERICA LLC'S OPPOSITION TO DEFENDANT GEORGE HOTZ'S MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION AND IMPROPER VENUE - CASE NO. 11-cv-000167 SI

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Dockets.Justia.com

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2.

SCEA's headquarters and principal place of business is at 919 East Hillsdale

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Boulevard, Foster City, California, 94404. SCEA conducts the vast majority of its business activities in California. All of SCEA's business units, including marketing, research and
development, financial, and consumer service departments are located in Foster City, CA.

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3.

SCEA is the exclusive distributor of the PlayStation@3 computer entertainment

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system ("PS3 System") in the United States. SCEA's activities relating to the marketing, sale
and distribution of the PS3 System in the United States are based out of Foster City, CA.

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4.

The PS3 System also features PlayStation@ Network ("PSN"), an entertainment

network that supports multiplayer online gameplay, access to the PlayStation Store, and PS3 System connectivity. SCEA's activities related to the PSN are based out of Foster City, CA.

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5.

SCEA contracts to manage the servers that host the PSN for customers in the

United States. These servers are located in San Diego. Accordingly, when a user in the United States logs onto the PSN to create or access an account or to purchase PlayStation content, the user will normally be connected to a server located in California.

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SCEA also creates video games and other original content for the PS3 or PSN.

Most of SCEA's activities relating to the creation of these video games or other original
is conducted in Foster City or other SCEA studios in California (such as Santa Monica or San

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Diego). Further, several game servers that host online multiplayer video games created by
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SCEA are located in San Diego and Santa Monica, California.

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7.

SCEA's consumer service department is based in Foster City, CA. The

consumer service personnel located in Foster City, CA are the individuals responsible for operation of all of SCEA's consumer services call centers and resolution

of escalated

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questions or complaints from consumers within SCEA's distribution territory.
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declare under penalty of perjury under the laws of the United States that the

DECLARATION OF JENNIFER LIU IN SUPPORT OF PLAINTIFF. SONY COMPUTER ENTERTAINMENT AMERICA LLC'S OPPOSITION TO DEFENDANT GEORGE HOTZ'S MOTION TO DISMISS FOR LACK OF JURISDICTION AND IMPROPER VENUE - CASE NO. 11-cv-000167 Sl

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foregoing is true and correct to the best of my knowledge and belief.

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Executed on Marchl 8,2011, at Foster City, California.

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DECLARATION OF JENNIFER LIU IN SUPPORT OF PLAINTIFF. SONY COMPUTER ENTERTAINMENT AMERICA LLC'S OPPOSITION TO DEFENDANT GEORGE HOTZ'S MOTION TO DISMISS FOR LACK OF JURISDICTION AND IMPROPER VENUE - CASE NO. 11-cv-000167 Sl