Streetspace, Inc v. Google, Inc. et al

Filing 23

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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1 2 3 4 5 6 GOODWIN PROCTER LLP Kurt M. Kjelland (CSB No. 172076) 4365 Executive Drive, 3rd Floor San Diego, CA 92121 Telephone: 858.202.2728 Facsimile: 858.457.1255 Attorneys for Defendant JUMPTAP, INC. 7 8 UNITED STATES DISTRICT COURT 9 SOUTHERN DISTRICT OF CALIFORNIA 10 11 STREETSPACE, INC., a Delaware Corporation, 12 Plaintiff, 13 v. 14 15 16 17 18 19 20 21 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. 22 23 24 25 26 27 28 DECLARATION OF JUMPTAP CASE NO. 10-CV-1757 (LAB) 1 I, David Kahan, declare: 2 1. I am employed as General Counsel of JumpTap, Inc. (“Jumptap”), headquartered 3 in Cambridge, Massachusetts. I have been employed by Jumptap since 2006. I submit this 4 declaration on behalf of Jumptap in support of Defendants’ Motion to Transfer Venue to the 5 Northern District of California. Unless otherwise indicated below, the statements in this 6 declaration are based on either my personal knowledge or corporate records maintained by 7 Jumptap in the ordinary course of business. 8 9 10 11 12 13 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. 3. Jumptap provides mobile advertising technology services and operates a mobile advertising network. 4. I understand that in the Complaint filed against Jumptap and other Defendants, 14 Streetspace, Inc. (“Streetspace”) alleges that Jumptap infringes the patent-in-suit, but 15 Streetspace’s complaint does not specify or identify any particular Jumptap products or services 16 accused of infringing the patent-in-suit. 17 5. The research, design and development for Jumptap’s products and services takes 18 place primarily in Cambridge, Massachusetts, and virtually all of the documents and records 19 relating to the research, design and development of those products and services are located in 20 Cambridge, Massachusetts. All of the current Jumptap employees who have responsibilities for 21 the design and development of the Jumptap’s products and services reside in or near Cambridge, 22 Massachusetts or Tel Aviv, Israel. 23 6. Virtually all Jumptap business records relating to sales, pricing and revenue are 24 located in Cambridge or New York. Most of the employees who have responsibilities relating to 25 Jumptap sales reside in or near Cambridge or New York. 26 27 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. 28 -2- DECLARATION OF JUMPTAP CASE NO. 10-CV-1757 (LAB)

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