Streetspace, Inc v. Google, Inc. et al
Filing
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Joint MOTION for Change Venue by Admob, Inc, Apple, Inc., Google, Inc., Jumptap, Inc, Millennial Media, Inc, Quattro Wireless, Inc. (Attachments: # 1 Memo of Points and Authorities, # 2 Declaration of Apple Inc. and Quattro Wireless, Inc., # 3 Declaration of Google, Inc. and AdMob, Inc., # 4 Declaration of Jumptap, Inc., # 5 Declaration of Millennial Media, Inc., # 6 Declaration of Anne Huffsmith and Exhibits A - C, # 7 Proof of Service)(Simmons, Luann) (kaj).
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GOODWIN PROCTER LLP
Kurt M. Kjelland (CSB No. 172076)
kkjelland@goodwinprocter.com
4365 Executive Drive, 3rd Floor
San Diego, CA 92121
Telephone: 858.202.2728
Facsimile: 858.457.1255
Attorneys for Defendant
JUMPTAP, INC.
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UNITED STATES DISTRICT COURT
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SOUTHERN DISTRICT OF CALIFORNIA
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STREETSPACE, INC., a Delaware
Corporation,
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Plaintiff,
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v.
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GOOGLE INC., a Delaware Corporation,
ADMOB, INC., a Delaware Corporation,
APPLE INC., a California Corporation,
QUATTRO WIRELESS, INC., a Delaware
Corporation, NOKIA CORPORATION, a
foreign corporation, NOKIA INC., a
Delaware Corporation, NAVTEQ
CORPORATION, a Delaware Corporation,
MILLENIAL MEDIA, INC., a Delaware
Corporation, JUMPTAP, INC., a Delaware
Corporation, and DOES 1 though 20,
inclusive,
Case No. 10-CV-1757 (LAB)
DECLARATION OF JUMPTAP, INC.
IN SUPPORT OF MOTION TO
TRANSFER VENUE TO THE
NORTHERN DISTRICT OF
CALIFORNIA
Judge: Hon. Larry A. Burns
Hearing Date:
March 14, 2011
Time:
11:15 a.m.
Courtroom:
9, 2nd Floor
Action Filed:
August 23, 2010
Defendants.
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DECLARATION OF JUMPTAP
CASE NO. 10-CV-1757 (LAB)
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I, David Kahan, declare:
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1.
I am employed as General Counsel of JumpTap, Inc. (“Jumptap”), headquartered
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in Cambridge, Massachusetts. I have been employed by Jumptap since 2006. I submit this
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declaration on behalf of Jumptap in support of Defendants’ Motion to Transfer Venue to the
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Northern District of California. Unless otherwise indicated below, the statements in this
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declaration are based on either my personal knowledge or corporate records maintained by
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Jumptap in the ordinary course of business.
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2.
Jumptap is a Delaware corporation headquartered in Cambridge, Massachusetts.
Jumptap’s sales headquarters are in New York, New York, and Jumptap has a development office
in Tel Aviv, Israel.
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Jumptap provides mobile advertising technology services and operates a mobile
advertising network.
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I understand that in the Complaint filed against Jumptap and other Defendants,
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Streetspace, Inc. (“Streetspace”) alleges that Jumptap infringes the patent-in-suit, but
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Streetspace’s complaint does not specify or identify any particular Jumptap products or services
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accused of infringing the patent-in-suit.
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5.
The research, design and development for Jumptap’s products and services takes
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place primarily in Cambridge, Massachusetts, and virtually all of the documents and records
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relating to the research, design and development of those products and services are located in
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Cambridge, Massachusetts. All of the current Jumptap employees who have responsibilities for
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the design and development of the Jumptap’s products and services reside in or near Cambridge,
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Massachusetts or Tel Aviv, Israel.
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6.
Virtually all Jumptap business records relating to sales, pricing and revenue are
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located in Cambridge or New York. Most of the employees who have responsibilities relating to
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Jumptap sales reside in or near Cambridge or New York.
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7.
Jumptap has two employees working in the Northern District of California. One
employee is a Director of Business Development and the other is a Director of Ad Sales.
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DECLARATION OF JUMPTAP
CASE NO. 10-CV-1757 (LAB)
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