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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George A. Riley (SB# 118304) – [e-mail]
Luann L. Simmons (SB# 203526) – [e-mail]
Anne E. Huffsmith (SB# 236438) – [e-mail]
O’MELVENY & MYERS LLP
Two Embarcadero Center, 28th Floor
San Francisco, California 94111
Telephone:
[phone]
Facsimile:
[phone]

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6

Attorneys for Defendants
APPLE INC. and
QUATTRO WIRELESS, INC.

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8

UNITED STATES DISTRICT COURT

9

SOUTHERN DISTRICT OF CALIFORNIA

10
11

STREETSPACE, INC., a Delaware
Corporation,

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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 ANNE E.
HUFFSMITH IN SUPPORT OF
MOTION TO TRANSFER VENUE TO
THE NORTHERN DISTRICT OF
CALIFORNIA
Judge:
Hearing Date:
Time:
Courtroom:

Hon. Larry A. Burns
March 14, 2011
11:15 AM
9, 2nd Floor

Action Filed:

August 23, 2010

Defendants.

22
23
24
25
26
27
28
DECLARATION OF ANNE E. HUFFSMITH
CASE NO. 10-CV-1757 (LAB)

DECLARATION OF ANNE E. HUFFSMITH
IN SUPPORT OF MOTION TO TRANSFER VENUE
TO THE NORTHERN DISTRICT OF CALIFORNIA

TABLE OF CONTENTS TO EXHIBITS

Exhibit

Page Numbers

A

4-8

B

9 - 11

C

12 - 14

-3-

DECLARATION OF ANNE E. HUFFSMITH
IN SUPPORT OF MOTION TO TRANSFER VENUE TO
THE NORTHERN DISTRICT OF CALIFORNIA

EXHIBIT A

-4-

Kuala Lumpur to San Diego Flight Time | Flight Duration to San Diego from Kuala Lum...

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India Maps

Kuala Lumpur to San Diego Flight Time Calculator - Air Travel Time between Kuala Lumpur & San Diego
Home » Travel » Flight Time » From Kuala Lumpur Airport » To San Diego Airport
Calculate the Air Travel Time or the Flight Time from Kuala Lumpur to San Diego. Find out the total hours of air travel needed to reach Kuala Lumpur from San Diego.
Flying time on an airplane from San Diego Airport to Kuala Lumpur Airport.

Travel Tools
Airports Home
Airports in India

AIR TRAVEL TIME CALCULATOR - FLIGHT TIME BETWEEN KUALA LUMPUR AIRPORT & SAN DIEGO AIRPORT

1

FLIGHT TIME
CALCULATOR

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3

Given below is the Air Travel Time or the Flight duration between Kuala Lumpur and San Diego. This flight
Airports in US

AIRPORT IATA CODES

Airports in Canada

time calculator is helpful in finding the air travel time between any two cities in the world, in this case travel
time from Kuala Lumpur to San Diego. Flight time is calculated as the flying time from the nearest airports

London Heathrow
AIRPORT ICAO CODES

to the selected cities. The nearest airport to Kuala Lumpur, Malaysia, is Kuala Lumpur International

AIRPORTS & COUNTRIES

airport location map is also given below showing the air travel direction. To find air travel distance between

Airport and the nearest airport to San Diego, United States, is San Diego International Airport. . The
Airports in Australia
Los Angeles Airport, US

more cities, use the form given below the map.

Airport Distance

As per the inputs provided, the flight time or the hours of air travel required for a journey between Kuala
Lumpur International Airport and San Diego International Airport is 16 hours 3 minutes

Flight Time Calculator
Distance Calculator

Flight Time between San Diego International Airport and Kuala Lumpur International Airport
is :

16

World Time
Timezones
Jet Lag Calculator
Indian Railway

hours

3

minutes

Departure Time : Wed, 19 Jan, 2011, 04:07 AM
Arrival Time : Wed, 19 Jan, 2011, 04:10 AM
If you haven't provided any addition information, the departure time is taken as the current time at Kuala

India Maps
India Roads &
Highways
India River Map

Lumpur International Airport and the arrival time is the time at San Diego International Airport at the time of
your arrival there.

KUL to SAN - Route Map

Ganges River Map
India Airport Map
Railway Map of India
Blank Outline of India
India Tourist Map
Distance to India

Map data ©2011 Geocentre Consulting, MapLink, Tele Atlas, Whereis(R), Sensis Pty Ltd - Terms of Use

Find flight time from Kuala Lumpur International Airport or Kuala Lumpur or any other airport or city in
Malaysia to various other destinations around the world using this flight time calculator.

From

Kuala Lumpur International Airport, Malaysia

To

San Diego International Airport, United States
+ Show Additional Inputs

Submit

-5http://www.prokerala.com/travel/flight-time/

1/18/2011

Kuala Lumpur to San Diego Flight Time | Flight Duration to San Diego from Kuala Lum...

Page 2 of 2

Links to Other Sections

A list of major Cities/Airports around the world is given below. Click on any of the airport names given below
to find the flight distance from Kuala Lumpur to those airports.
» Dubai, Dubai Airport

» Melbourne, Tullamarine Airport

» Toronto, Lester B. Pearson International Airport

» Tokyo, Tokyo Haneda International Airport

» Cancun, Cancun International Airport

» Brasília, Distrito Federal, Presidente Juscelino
Kubitschek Airport

» Birmingham, Birmingham International Airport

» Edinburgh, Turnhouse Airport

» Copenhagen, Kastrup Airport

» Oakland, Oakland International Airport

Finding flight time between cities is important while planning a trip. This will help you schedule your trip
perfectly. Kuala Lumpur to San Diego air travel distance is given above. This information will give you an
idea about the hours of flight needed to reach San Diego, United States from Kuala Lumpur, Malaysia.
Using this air travel time calculator you can find the flying hours between Kuala Lumpur International Airport
and San Diego International Airport on a direct flight as well as on an indirect flight with intermediate
stopovers.
India News | Kerala News | Bollywood Movies | Daily Horoscope | Kerala Pictures | India Pin Codes | ISD Codes | India STD Codes | Kerala Recipes |
Online Games | Videos | Greeting Cards | Chinese New Year Dates | Vastu Shastra | Feng Shui | Chinese Birth Chart | Baby Names

© 2011 Prokerala.com

Terms of service | Disclaimer

-6http://www.prokerala.com/travel/flight-time/

1/18/2011

Kuala Lumpur to San Francisco, CA Flight Time | Flight Duration to San Francisco, CA f... Page 1 of 2

Home

Top News

Chinese Calendar

Ayurveda

Yoga

About Kerala

Indian Movies

Watch Videos

Downloads

Airports

India Maps

Kuala Lumpur to San Francisco, CA Flight Time Calculator - Air Travel Time between Kuala Lumpur &
San Francisco, CA
Home » Travel » Flight Time » From Kuala Lumpur Airport » To San Francisco, CA Airport
Calculate the Air Travel Time or the Flight Time from Kuala Lumpur to San Francisco, CA. Find out the total hours of air travel needed to reach Kuala Lumpur from
San Francisco, CA. Flying time on an airplane from San Francisco, CA Airport to Kuala Lumpur Airport.

Travel Tools
Airports Home
Airports in India

AIR TRAVEL TIME CALCULATOR - FLIGHT TIME BETWEEN KUALA LUMPUR AIRPORT & SAN FRANCISCO, CA AIRPORT

1

FLIGHT TIME
CALCULATOR

retweet

Like

3

Given below is the Air Travel Time or the Flight duration between Kuala Lumpur and San Francisco, CA.
Airports in US

AIRPORT IATA CODES

Airports in Canada

This flight time calculator is helpful in finding the air travel time between any two cities in the world, in this
case travel time from Kuala Lumpur to San Francisco, CA. Flight time is calculated as the flying time from

London Heathrow
AIRPORT ICAO CODES

the nearest airports to the selected cities. The nearest airport to Kuala Lumpur, Malaysia, is Kuala Lumpur
International Airport and the nearest airport to San Francisco, CA, United States, is San Francisco

Airports in Australia

AIRPORTS & COUNTRIES

International Airport. . The airport location map is also given below showing the air travel direction. To

Los Angeles Airport, US

find air travel distance between more cities, use the form given below the map.

Airport Distance

As per the inputs provided, the flight time or the hours of air travel required for a journey between Kuala
Lumpur International Airport and San Francisco International Airport is 15 hours 16 minutes

Flight Time Calculator
Distance Calculator

Flight Time between San Francisco International Airport and Kuala Lumpur International
Airport is :

15

World Time
Timezones
Jet Lag Calculator
Indian Railway

hours

16

minutes

Departure Time : Wed, 19 Jan, 2011, 04:08 AM
Arrival Time : Wed, 19 Jan, 2011, 03:24 AM
If you haven't provided any addition information, the departure time is taken as the current time at Kuala

India Maps
India Roads &
Highways
India River Map

Lumpur International Airport and the arrival time is the time at San Francisco International Airport at the
time of your arrival there.

KUL to SFO - Route Map

Ganges River Map
India Airport Map
Railway Map of India
Blank Outline of India
India Tourist Map
Distance to India

Map data ©2011 Geocentre Consulting, MapLink, Tele Atlas, Whereis(R), Sensis Pty Ltd - Terms of Use

Find flight time from Kuala Lumpur International Airport or Kuala Lumpur or any other airport or city in
Malaysia to various other destinations around the world using this flight time calculator.

From

Kuala Lumpur International Airport, Malaysia

To

San Francisco International Airport, United States
+ Show Additional Inputs

-7http://www.prokerala.com/travel/flight-time/

1/18/2011

Kuala Lumpur to San Francisco, CA Flight Time | Flight Duration to San Francisco, CA f... Page 2 of 2

Links to Other Sections

Submit

A list of major Cities/Airports around the world is given below. Click on any of the airport names given below
to find the flight distance from Kuala Lumpur to those airports.
» Singapore, Changi Airport

» Dallas, TX, Dallas/Fort Worth International Airport

» Brisbane, Brisbane International Airport

» Curitiba, Afonso Pena International Airport

» Brasília, Distrito Federal, Presidente Juscelino
Kubitschek Airport

» Auckland, Auckland International Airport

» Abuja, Nnamdi Azikiwe International Airport

» Luton, London Luton Airport

» Miami, Miami International Airport

» Guernsey, Guernsey Airport

Finding flight time between cities is important while planning a trip. This will help you schedule your trip
perfectly. Kuala Lumpur to San Francisco, CA air travel distance is given above. This information will give
you an idea about the hours of flight needed to reach San Francisco, CA, United States from Kuala Lumpur,
Malaysia. Using this air travel time calculator you can find the flying hours between Kuala Lumpur
International Airport and San Francisco International Airport on a direct flight as well as on an indirect flight
with intermediate stopovers.
India News | Kerala News | Bollywood Movies | Daily Horoscope | Kerala Pictures | India Pin Codes | ISD Codes | India STD Codes | Kerala Recipes |
Online Games | Videos | Greeting Cards | Chinese New Year Dates | Vastu Shastra | Feng Shui | Chinese Birth Chart | Baby Names

© 2011 Prokerala.com

Terms of service | Disclaimer

-8http://www.prokerala.com/travel/flight-time/

1/18/2011

DECLARATION OF ANNE E. HUFFSMITH
IN SUPPORT OF MOTION TO TRANSFER VENUE TO
THE NORTHERN DISTRICT OF CALIFORNIA

EXHIBIT B

-9-

>STREETSPACE.

Page 1 of 2

The Clicks-and-Mortar Network™
>STREETSPACE. offers the first truly connected
network of Web-based kiosks for retail locations.
Our breakthrough solution fulfills each of the
following unmet needs:
Retailers need to build a strong online presence
Consumer Product Manufacturers and
Distributors need to increase effectiveness of instore merchandising
E-tailers need to build brand awareness and
reach new customers
Content Portals need to obtain more eyeballs
and increase repeat traffic
ISPs need to acquire new users
Consumers need free and continuous online
access
>STREETSPACE. FEATURES
In order to encourage fast adoption and ubiquity,
>STREETSPACE. is 100% free to the user. The user
stays within our "walled garden of content" at all
times.
Partner-Specific Content (i.e.
TowerRecords.com or Coca-cola.com)
Online Shopping (books, CDs, tickets,
groceries, etc.)
E-Mail (including 3rd-party email providers:
Yahoo!, AOL, HotMail)
Classifieds (rooms, cars, local events, etc.)
Music (music samples, CD search, videos,
reviews, articles)
Film (movie trailers, film clips, reviews,
articles)
News (up-to-the-minute headlines and stories)
Sports (all the latest scores, stats, and
highlights)
- 10 http://web.archive.org/web/20000511125303/www.streetspace.com/intro.htm

1/4/2011

>STREETSPACE.

Page 2 of 2

Local City Guide (local listings, directions,
maps)
Personal Calendar
Personal Phonebook
STREET LINC:
THE CLICKS-AND-MORTAR KIOSK™
Working with IDEO Design, the world's leading
product design firm, we have developed a unique
Web-based kiosk called the Street Linc for
deployment in retail spaces all over the country. The
Street Linc's curvy, 21st century design is sleek,
inviting, and fits easily into a wide range of retail
environments.
Made of cast aluminum, the
Street Linc includes a
touchscreen (no mouse
necessary), a full keyboard
(spill-proof), stereo speakers,
stereo headphones, and a
drink tray. The Street Linc is
connected to our network with a digital subscriber line
(DSL), allowing for a rich, compelling online
experience. A smart card reader is built into the
system to facilitate transactions and loyalty program
tie-ins in the future.
THE BERKELEY VALIDATION NETWORK
In order to validate our network before expanding the
>STREETSPACE. network nationwide, over 60
Street Lincs have already been deployed in retail
spaces throughout downtown Berkeley, CA. They
have been up and running since last October, and they
are in use today by nearly 20,000 registered users. The
Street Lincs have been placed in high-traffic locations
all over town, including Tower Records, Reel Video
(owned by Hollywood Video and an extension of
Reel.com), Amoeba Music, Fine Arts Cinema, Cody's
Books, and Bear's Lair (on UC Berkeley's campus).
>STREETSPACE. has literally achieved ubiquity in
Berkeley. Of course, Berkeley is only the beginning.
We are now ready to expand our network nationwide.

- 11 http://web.archive.org/web/20000511125303/www.streetspace.com/intro.htm

1/4/2011

DECLARATION OF ANNE E. HUFFSMITH
IN SUPPORT OF MOTION TO TRANSFER VENUE TO
THE NORTHERN DISTRICT OF CALIFORNIA

EXHIBIT C

- 12 -

HighBeam Research

Page 1 of 2

>STREETSPACE to Offer Free Web Access Via
Private Network in Retail Locations.
Article from: PR Newswire

Article date: August 4, 2000

SAN FRANCISCO, Aug. 4 /PRNewswire/ ->STREETSPACE, the first company to offer consumers free access to Web-based content
in retail locations over a private network, is poised to expand to major markets, starting with
San Francisco. For the last 9 months, consumers in Berkeley, CA have been accessing
>STREETSPACE's free Web-based services in cafe's, book stores, record stores, and
restaurants via stylishly designed Web Stations(TM).
Four weeks ago, the company introduced a new version of its offering in over 40 high-traffic
retail locations in Berkeley, including Tower Records, Amoeba Music, Cody's Books, Reel
Video, Royal Ground Cafe, and Smart Alec's restaurant. >STREETSPACE users now have
free access to major websites like HotMail, CitySearch, FOXSports.com, and ABC
News.com, plus content that focuses on U.C. Berkeley. With minimal marketing in
Berkeley, >STREETSPACE has already enticed over 30,000 people to register there, which
represents close to one third of the city's total population. Now, >STREETSPACE is looking
to roll out its network in larger cities by partnering with national retail chains.
With the built-in limitations of PDAs and mobile phones today -- low bandwidth, cost of
hardware, service charges, tiny screen, and lack of a usable keyboard -- the idea of placing
Web-based kiosks in public places has caught fire in the marketplace. According to a report
released by Forrester Research in June, 80% of retailers are planning to have Web-based
kiosks in most of their stores by 2002.
"We're creating a new category here," says founder Tom Mathai. "With the millions of
people accessing the Internet every day, we decided to address consumers' desire for
online access when they don't happen to be at home or work. The need for access doesn't
just go away because you walk out the door. So, we are building a network in the retail
space to fill that need."
>STREETSPACE's strategy is to help retailers leverage their brick and mortar space to
build presence for their online offerings. The company offers retailers a free end-to-end
solution that includes installation of the Web Stations and the high-speed Internet
connection, network management, customer service, maintenance, cleaning, and usage
reporting. The retailer's online offering is displayed prominently on the Web Station screen,
and retailers retain 100% of any sales generated from their sites.
In San Francisco, the launching pad for >STREETSPACE's private network will be the new
home of the San Francisco Giants, Pacific Bell Park. Starting tonight, fans attending home
games will have free access to Giants-specific content and other popular websites.
Additionally, >STREETSPACE will soon be announcing pilot programs with some of the
most recognized brick and mortar retail chains.
"The fact that we take care of everything for our retail partners makes our Clicks-and-Mortar
Network solution very attractive. Building a private broadband network in retail locations is
technically and operationally complex. By working with us, the retailers don't have to lift a
finger, nor do they have to pay," says Vice President of Marketing at >STREETSPACE,
Michael Wranovics. "Additionally, we give them a percentage of the revenue generated by
Web Stations in their locations."
The company will earn revenue by offering sponsorships to dot-com companies who will
have the opportunity to build their brands, acquire new users, and retain them by making
their sites prominent and accessible in retail locations. "We could make Schwab.com the
exclusive online trader accessible in 40 high-traffic retail locations for less than the cost of a
standard billboard," says Wranovics. "The key differentiator is that people can actually
experience the Schwab site, become registered users, and conduct trades on a Web
Station. All a billboard can do is remind you that the company exists."
About >STREETSPACE
On October 22, 1999, >STREETSPACE launched the first Clicks-and-Mortar Network(TM)
with over 60 high-traffic retail locations in Berkeley, CA. >STREETSPACE, which is now
poised to expand its private broadband network nationally, is helping retail businesses
leverage their physical space to build a stronger online presence and provide their
customers with free online access. The >STREETSPACE offering consists of compact,
stylishly designed Web Stations connected to a private broadband network. Standard
features on a Web Station include the retail partner's online offering, plus free access to email, a city guide, news, sports, online shopping, and other popular online offerings.

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HighBeam Research

Page 2 of 2

COPYRIGHT 2009 PR Newswire Association LLC. This material is published under license from the publisher through the
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