Streetspace, Inc v. Google, Inc. et al

Filing 41

REPLY to Response to Motion re 23 Joint MOTION for Change Venue filed by Apple, Inc., Jumptap, Inc, Millennial Media, Inc, Navteq Corporation, Nokia Corporation, Nokia Inc, Quattro Wireless, Inc. (Attachments: # 1 Declaration Anne E. Huffsmith in Support, # 2 Exhibit D to the Declaration of Anne E. Huffsmith, # 3 Proof of Service)(Simmons, Luann) (lmt).

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

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Additional parties and counsel listed in the signature block

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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,
Plaintiff,

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v.
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)
REPLY IN SUPPORT OF MOTION TO
TRANSFER VENUE TO THE
NORTHERN DISTRICT OF
CALIFORNIA
Judge:
Hearing Date:
Time:
Courtroom:

Hon. Larry A. Burns
March 14, 2010
11:15 AM
9, 2nd Floor

Action Filed:

August 23, 2010

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Defendants.
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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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I.

INTRODUCTION

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Plaintiff does not contest in its Opposition that its sole basis for filing the present case in

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the Southern District of California is that Plaintiff’s attorneys are located there. But the location

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of Plaintiff’s attorneys is wholly irrelevant to the transfer inquiry. Plaintiff cannot provide a

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single additional reason why this case should proceed in the Southern District of California,

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except to state that Defendants’ allegedly-infringing products are available for purchase there.

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This reason is not persuasive, however, as Defendants’ allegedly-infringing products are available

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for purchase in every federal judicial district in the United States. Plaintiff also seeks to show

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that the Southern District of California is a convenient forum for Defendants by arguing that

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Defendants Apple and Google litigate all over the country, and Defendant Nokia has a research

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facility in San Diego. But Apple’s and Google’s other litigations arise from vastly divergent facts

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and legal issues none of which are relevant to this case, and Nokia’s accused functionality—

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Nokia Maps—is not developed in its San Diego facility.

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As explained in Defendants’ Opening Motion, there are numerous legitimate reasons why

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the Northern District of California is a far more convenient forum in which to litigate this case—

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various party and non-party witnesses are located in the Northern District of California, many of

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the allegedly-infringing products were developed in the Northern District of California, numerous

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relevant documents are located in the Northern District of California1, and more than half of the

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named Defendants are headquartered or have offices in the Northern District of California.

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Accordingly, Defendants’ Motion should be granted and this case should be transferred to the

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Northern District of California.

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Plaintiff argues in its Opposition that the location of relevant documents is irrelevant to the transfer inquiry. Dkt.
No. 33 at 15-16. This is simply not true. Courts in the Ninth Circuit consider the location of relevant documents in
determining whether transfer is appropriate. See In re National Consumer Mortg. LLC., No. SA CV 10-0159, 2010
WL 2384217, at *6 (C.D. Cal. Jun. 10, 2010) (“Because [defendant] is a resident of Nevada and all of the relevant
documents are located in Las Vegas, litigating in the District of Nevada would be more convenient ….”) (emphasis
added); Rowsby v. Gulf Stream Coach, Inc., No. SA CV08-1213, 2009 WL 1154130, at *4 (C.D. Cal. Feb. 9, 2009)
(“[T]ransfer pursuant to § 1404(a) is appropriate because Gulf Stream witnesses and documents regarding
manufacture of the motor home are located in Indiana.”) (emphasis added).

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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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II.

ARGUMENT

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A.

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Plaintiff argues that the Southern District of California is more convenient than the

The Location of Streetspace’s Counsel Is Irrelevant to the Transfer Inquiry.

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Northern District of California because Plaintiff’s counsel are located in San Diego. As

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Defendants point out in their Opening Motion, however, the location of Plaintiff’s counsel is

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irrelevant to the transfer inquiry. Dkt. No. 23 at 7-8 (citing Panetta v. SAP America, Inc.,

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No. C0501696RMW, 2005 WL 1774327, at *5 (N.D. Cal. July 26, 2005) (“[T]he location of

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plaintiff’s counsel is immaterial to a determination of the convenience and justice of a particular

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forum.”); Soloman v. Cont. Amer., 472 F .2d 1043, 1047 (3d Cir. 1973) (“The convenience of

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counsel is not a factor to be considered.”); In re Horseshoe Ent., 305 F.3d 354, 358 (5th Cir.

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2002) (The factor of “location of counsel” is irrelevant and improper for consideration in

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determining the question of transfer of venue.”); Peacock v. Willis, No. CV F 06-432 AWI LJO,

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2006 WL 3060134, at *12 (E.D. Cal. Oct. 27, 2006) (citing In re Volkswagen AG, 371 F.3d 201,

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206 (5th Cir. 2004)) (“In the context of a 28 U.S.C. § 1404 motion, the location of a party’s

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attorney is generally not considered.”)); see also Zhejiang Ouhai Int’l Trade Corp. v. Southern

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Cal. Valve Equipment Co., Inc., No. C-09-03360, 2009 WL 4981144, at *4 (N.D. Cal. Dec. 16,

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2009) (“[C]onvenience of counsel, or the need to engage new counsel in the transferee state, is

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not a valid consideration.”) (citing Panetta, 2005 WL 1774327 at *5; Winward v. Pfizer, Inc.,

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Nos. C 07-0878 & C 07-0879, 2007 U.S. Dist. LEXIS 82885, at *11 (N.D.Cal.2007) (“The

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location of counsel and the need to retain counsel in the transferee district is of little, if any

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weight in considering a motion to transfer pursuant to section 1404(a)”)); Szegedy v. Keystone

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Food Products, Inc., No. CV 08-5369, 2009 WL 2767683, at *6 fn. 4 (C.D. Cal. Aug. 26, 2009)

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(“[T]he location of plaintiff’s counsel is immaterial to a determination of the convenience and

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justice of a particular forum.”) (citations and internal quotations omitted).

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Plaintiff cites a single case in its Opposition as putative support for its argument that this

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Court should, notwithstanding all relevant authority to the contrary, refuse to transfer this case

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based on the location of Plaintiff’s counsel. Dkt. No. 33 at 12 (citing Blumenthal v. Mgmt.

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Assistance, Inc., 480 F.Supp. 470, 474 (N.D. Ill. 1979)). But even if the cited 1979 Illinois
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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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opinion, applying Seventh Circuit law, had any bearing on this Court’s application of Ninth

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Circuit law to the pending motion, that opinion still would not support Streetspace’s argument. In

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Blumenthal, the court stated that “[n]either the convenience of counsel nor the convenience of

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expert witnesses is a factor in determining the disposition of a 1404(a) motion.” Id. at 474. The

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court added, though, that the named plaintiffs in the case—who were individuals, not companies,

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as in this case—did not have counsel in the requested transferee jurisdiction and would, therefore,

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have to pay for new counsel and for the transportation of their existing counsel. Under those

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specific circumstances, this court held that the added cost of litigation for these individual

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plaintiffs was “a factor to consider.” Id.

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Here, by contrast, all of the parties are companies, not individuals. The rationale behind

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the decision in Blumenthal is, therefore, not applicable. But if this Court were to consider the

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cost of litigation to each party as a “factor” in its analysis, that factor would, at best, be neutral.

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Defendants Apple and Quattro Wireless have retained counsel who are all located in the Northern

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District of California and do not have an office in the Southern District of California. Requiring

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Apple’s and Quattro Wireless’ attorneys to litigate a trial in the Southern District of California

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will be at least as expensive as requiring Streetspace’s attorneys to litigate a trial in the Northern

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District of California.

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The location of Streetspace’s counsel, therefore, does not weigh against transferring this
case to the Northern District of California.
B.

The Northern District of California is a More Convenient Forum for All
Identified Witnesses.

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Streetspace does not identify a single witness for whom that Southern District of

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California is a more convenient forum than the Northern District of California. Instead,

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Streetspace argues that the convenience of the witnesses identified by Defendants is irrelevant

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because (1) the non-party witnesses are within the subpoena power of the Court, (2) the party-

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witnesses “are available in any venue,” and (3) “Defendants have not … specified the identity or

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location of any witnesses, or the content of the anticipated testimony.” Dkt No. 33 at 11-16.

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Each of these arguments is without merit.
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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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Plaintiff is correct that non-parties may be compelled to travel more than 100 miles to

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testify, if such travel occurs within the state.2 See F.R.C.P. 45(c)(3)(A)(ii). Non-party witnesses

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will not be compelled to travel more than 100 miles, however, when the non-party will “incur

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substantial expense to travel more than 100 miles to attend trial.” F.R.C.P. 45(c)(3)(B)(iii). If

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this case is not transferred to the Northern District of California, the identified non-party

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witnesses will be forced to travel approximately 500 miles from Berkeley, California to San

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Diego, California to testify. This magnitude of travel will undoubtedly result in substantial

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expense to these non-parties. See Heavy Petroleum Partners, LLC v. Atkins, No. 09-1077, 2010

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WL 398089, at *3 (D. Kan. Jan. 25, 2010) (holding that in-state non-party witnesses who would

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have to travel more than 100 miles to attend trial weighed in favor of transfer because they could

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move to quash pursuant to Rule 45(c)(3)(B)(iii)).

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Even if these witnesses could be compelled to attend trial, it is undisputed that the

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Northern District of California would be significantly more convenient for the witnesses. “The

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convenience of witnesses is often the most important factor in deciding whether to transfer an

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action pursuant to § 1404(a).” Cordua v. Navistar Intern. Transp. Corp., No. C 10-04961, 2011

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WL 62493, at *4 (N.D. Cal. Jan. 7, 2011) (emphasis added) (citing Getz v. Boeing Co., 547

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F.Supp.2d 1080, 1083 (N.D.Cal. 2008)); see also Skyriver Technology Solutions, LLC v. OCLC

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Online Computer Library Center, Inc., No. C 10-03305, 2010 WL 4366127, at *4 (N.D.Cal. Oct.

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28, 2010) (quoting Saleh v. Titan Corp., 361 F.Supp.2d 1152, 1160 (S.D.Cal. 2005)

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(“‘Importantly, while the convenience of party witnesses is a factor to be considered, the

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convenience of non-party witnesses is the more important factor.’”)). Plaintiff does not and

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cannot dispute that it would be exceedingly inconvenient for the numerous identified party and

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non-party witnesses who live and work in the Northern District of California to travel

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approximately 500 miles to testify at a trial held in the Southern District of California.

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Finally, Plaintiff’s argument that “Defendants have not … specified the identity or

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location of any witnesses, or the content of the anticipated testimony” suggests that Plaintiff has

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Defendants inadvertently misstated this rule in their Opening Motion, contending that non-parties could not be
compelled to travel more than 100 miles to testify. Dkt. No. 23 at 12.

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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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not thoroughly reviewed Defendants’ Motion. Defendants set forth clearly in their Motion the

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locations of the anticipated witnesses and the content of their testimony:

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All of the Apple employees who have responsibilities for the design and
development of the accused Apple/Quattro product, the iAd Network, are in
Cupertino. These witnesses will provide testimony relevant to Streetspace’s
infringement allegations against Apple and Quattro. Similarly, all of the Apple
employees who have responsibilities relating to iAd Network marketing and sales
are also in Cupertino. These witnesses will provide testimony relevant to
Streetspace’s allegations of damages caused by Apple and Quattro. Dkt. No. 23
at 10 (emphasis added).

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All of the Google and AdMob employees who have responsibilities for the design
and development of the accused Google/AdMob products, AdWords, AdSense,
Google Mobile Ads, and Android, are in Mountain View. These witnesses will
provide testimony relevant to Streetspace’s infringement allegations Google and
AdMob. Dkt. No. 23 at 10 (emphasis added).

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Defendants will seek testimony from non-party witnesses with information about
Streetspace’s “Street Linc” implementation. Specifically, Defendants have
identified the following companies who were involved in this implementation and
are, therefore, likely to have information relevant to this case: Amoeba Music—
located in Berkeley, California; Bear’s Lair—located in Berkeley, California;
Royal Grounds Café—located in Berkeley, California; Smart Alec’s Restaurant—
located in Berkeley, California Dkt. No. 23 at 11 (emphasis added).

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Defendants also adequately identify the anticipated witnesses for purposes of the transfer motion

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as “Apple employees who have responsibilities for the design and development of the accused

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Apple/Quattro product, the iAd Network,” “Apple employees who have responsibilities relating

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to iAd Network marketing and sales,” “Google and AdMob employees who have responsibilities

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for the design and development of the accused Google/AdMob products, AdWords, AdSense,

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Google Mobile Ads, and Android,” and 30(b)(6) witnesses from Amoeba Music, the Bear’s Lair,

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Royal Grounds Café, and Smart Alec’s Restaurant. Dkt. No. 23 at 10-11. Because this case is

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still in its very early stages, it is not possible for Defendants to identify these anticipated

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witnesses by name—for example, the non-party 30(b)(6) witnesses will be named by the

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corporations identified above in response to subpoenas that have not yet been served. These

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witnesses, however, will necessarily fall within the categories of persons described above, all of

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whom live and work in the Northern District of California.
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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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C.

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Plaintiff relies heavily on the fact that Defendants Google and Apple litigate cases in

Defendants’ Other Litigation Is Irrelevant to the Transfer Inquiry.

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forums around the country to oppose Defendants’ Motion. Dkt. No. 33 at 12-13. But Plaintiff

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makes no effort to explain how any of these other litigations is relevant to the allegations

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underlying the present action. Id. Apple and Google are large companies that develop and

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market numerous technologies all over the country and internationally. The various litigations in

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which they are involved, thus, arise from vastly divergent facts and legal issues. The transfer

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inquiry, to the contrary, is heavily dependent on the facts of the present case. See Atkins v. Magic

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Sliders, L.P., No. 10-cv-1533, 2010 WL 5174539, at *2 (S.D. Cal. Dec. 15, 2010) (citing Jones v.

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GNC Franchising, Inc., 211 F.3d 495, 498 (9th Cir. 2000)) (“A motion for transfer pursuant to

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§1404(a) lies within the discretion of the district court, and its outcome depends on the facts of

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each case.”) (emphasis added); Gonzales v. Palo Alto Labs, Inc., No. C 10-2456, 2010 WL

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3930440, at *7 (N.D. Cal. Oct. 6, 2010) (citing Jones, 211 F.3d at 498) (“In the Ninth Circuit, the

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decision to transfer pursuant to § 1404(a) lies within the discretion of the district court and

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depends on the facts of each particular case.”) (emphasis added). That Apple and Google are

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involved in other cases in other parts of the country involving completely different facts and legal

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issues has no bearing on a determination of which forum is the most convenient in which to

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litigate this case.

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The irrelevance of other litigation to the present action is highlighted by the Motion to

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Transfer Venue from the Eastern District of Virginia to the Southern District of California in SPH

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America v. Acer, Inc., et al., Case No. 1:09-cv-740 (E.D. Va.), which was joined by Apple (a

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defendant in that action) and is referenced no less than three times in Plaintiff’s Opposition. Dkt.

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No. 33 at 1-2, 4, 13. The specific circumstances surrounding the SPH America case—none of

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which exist in the present case—made the Southern District of California a dramatically more

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convenient forum in which to litigate that case.3 First, an earlier action filed by SPH America

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The same is true with respect to Apple’s oppositions to motions to transfer in Apple, Inc. v. HTC, Case No. C.A.
No. 10-544 (D. Del.) and Apple v. Unova, Case No. No. Civ.A. 03-101 (D. Del.), both cited by Plaintiff in its
Opposition. Dkt. No. 33 at 12-13. In HTC, another case involving the same legal issues was already pending in the
Delaware court. In Unova, three of the four named defendants were Delaware corporations. In this case, to the

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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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involving many of the same facts and legal issues had already been transferred to and was

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pending in Southern District of California. Second, the accused technology was found primarily

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in Qualcomm chips, and Qualcomm is based in the Southern District of California. Third,

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Qualcomm was not a party to the case, so critical non-party Qualcomm witnesses were outside

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the subpoena power of the Eastern District of Virginia. In this case, to the contrary, Apple’s

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relevant technology is developed in the Northern District of California, and all identified third

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party witnesses live and work in the Northern District of California. The Northern District of

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California is, thus, the more convenient forum.

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D.

The Public Interest Factors Are Neutral.

Plaintiff incorrectly accuses Defendants of “ignor[ing]” relevant public interest factors in

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their analysis. Dkt. No. 33 at 16-18. Defendants, however, analyzed all factors considered

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relevant by the Ninth Circuit in Jones v. GNC Franchising, Inc., 211 F.3d 495, 498-99 (9th Cir.

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2000), as well as numerous district courts in the Ninth Circuit. See Cordua v. Navistar Int’l

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Transportation Corp., No. C 10-04961, 2011 WL 62493 (N.D. Cal. Jan. 7, 2011) (in deciding a

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motion to transfer, the court did not consider in the public interest factors cited by Plaintiff);

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Johansson v. Central Garden & Pet Co., No. C 10-03771, 2010 WL 4977725 (N.D. Cal. Dec. 2,

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2010) (same); Ansel Adams Pub. Rights Trust v. PRS Media Partners, LLC, No. C 10-03740,

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2010 WL 4974114 (N.D. Cal. Dec. 01, 2010) (same); Barnstormers, Inc. v. Wing Walkers, LLC,

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No. 09-cv-2367, 2010 WL 2754249 (S.D. Cal. Jul. 09, 2010) (same). To the extent that

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Plaintiff’s additional public interest factors are relevant to the transfer inquiry, these factors are at

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most neutral.

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The public interest factors cited by Streetspace in its Opposition include “relative degrees

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of court congestion, the local interest in deciding local controversies, the burden on citizens of an

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unrelated forum with jury duty, and potential conflicts of law issues.” Dkt. No. 33 at 16. To

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show that the Northern District of California is more congested than the Southern District of

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California, Streetspace relies only on the total number of civil cases currently pending in each

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contrary, there is no related litigation pending in any forum, and Streetspace is a foreign corporation with its principal
place of business in Malaysia.

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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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jurisdiction. Dkt. No. 33 at 16. This measure does not take into account the complexity of these

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cases, however, or their relative times to trial. In a recent article authored by Stanford Professor

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Mark Lemley, Professor Lemley assessed the time to trial for patent cases brought in the Northern

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and Southern Districts of California at 2.92 and 2.48 years, respectively. Huffsmith Decl., Ex. D

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at Table 6. Thus, the difference in time to trial between the two forums is insignificant, rendering

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this factor neutral. With respect to the remaining three public interest factors, Streetspace

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acknowledges in its Opposition that they are neutral. Dkt. No. 33 at 17 (“Because Defendants’

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products are available nationwide … this Court has as much interest in deciding this case as any

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other …. Further, there can be no conflict of laws between courts in the same district.”)

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Accordingly, these factors do not weigh against transfer.

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E.

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Plaintiff argues that the Southern District of California is a convenient forum because

The Other Factors Relied On By Streetspace Are, At Best, Neutral.

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Defendants’ products are available for purchase there. But as Plaintiff acknowledges in its

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Opposition, Defendants’ products are available for purchase nationwide. Dkt. No. 33 at 17. This

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factor is, thus, neutral to the transfer inquiry. The fact that many of the accused products are

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developed in the Northern District of California, however, weighs in favor of transfer. Dkt. No.

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Plaintiff’s argument that its choice of forum should be given substantial weight is wrong

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as a matter of law. Plaintiff does not even attempt to respond to or distinguish the case law cited

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in Defendants’ Opening Motion, all of which makes clear that Plaintiff’s choice of forum is

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entitled to minimal deference where, as here, “plaintiff initiates an action in a state in which he or

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she is not a resident,” and “the transactions giving rise to the action lack a significant connection

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to the plaintiff’s chosen forum.” Dkt. No. 23 at 7 (citing Panetta v. SAP America, Inc.,

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No. C0501696RMW, 2005 WL 1774327, at *5 (N.D. Cal. July 26, 2005); Callaway Golf Co. v.

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Corporate Trade Inc., No. 09-cv-384, 2010 WL 743829, at *5 (S.D. Cal. Mar. 1, 2010)). Instead,

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Plaintiff relies on a host of other cases, none of which support its position. Dkt. No. 33 at 7

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(citing Safarian v. Maserati North America, Inc., 559 F. Supp. 2d 1068, 1072 (C.D. Cal. 2008)

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(considering plaintiff’s choice of forum when determining whether to transfer venue from the
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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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Southern to Western Division of the Central District of California, which are located only a

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“modest distance” apart); Florens Container v. Cho Yang Shipping, 245 F. Supp. 2d 1086, 1092

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(N.D. Cal. 2002) (considering plaintiff’s choice of forum where plaintiff’s principal place of

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business was located in that forum); E. & J. Gallo Winery v. F. & P.S.p.A, 899 F. Supp. 465, 467

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(E.D. Cal. 1994) (considering planitiff’s chosen forum where plaintff’s “headquarters, witnesses,

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and documents” were located in that forum); Accentra, Inc. v. Staples, Inc., Case No. CV 07-

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5862, 2008 U.S. Dist. LEXIS 112183, at *15 (C.D. Cal. Feb 27, 2008) (considering plaintiffs’

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choice of forum where one plaintiff’s “day-to-day operations” occurred in the forum and “several

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of its key personnel live[d]” in the forum,” and the other plaintiff “claim[ed] significant contacts

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with” the forum); Continental Cas. Co. v. American Home Assurance Co., 61 F. Supp. 2d 128,

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131 (D. Del. 1999) (stating explicitly that “the transfer of a case will generally be regarded as less

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inconvenient to a plaintiff if the plaintiff has not chosen its home turf or a forum where the

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alleged wrongful activity occurred.”) (emphasis added).)

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Finally, Plaintiff relies on the fact that Nokia has a research facility in the Southern

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District of California to argue that the Southern District of California is a more convenient forum.

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Dkt. No. 33 at 14. But as with its arguments regarding Apple’s and Google’s other litigations,

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Plaintiff makes no effort to link this facility to the allegations underlying the present action. And,

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in fact, Nokia has confirmed that the accused functionality—Nokia Maps—is not developed in its

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San Diego facility. Thus, the existence of this facility should have no bearing on the transfer

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inquiry.

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III.

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CONCLUSION
For the foregoing reasons, Defendants respectfully request that their Motion to Transfer

Venue to the Northern District of California be granted.

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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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Dated: March 7, 2011

By: /s/ Luann L. Simmons
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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Attorneys for Defendants APPLE INC. and
QUATTRO WIRELESS, INC.
/s/ John S. Kyle
John S. Kyle (CA 199196)
[e-mail]
4401 Eastgate Mall
San Diego, California 92121
Telephone: [phone]
Facsimile:
[phone]
Frank V. Pietrantonio
[e-mail]
Christopher C. Campbell
[e-mail]
One Freedom Square
11951 Freedom Drive
Reston, VA 20190-5656
Telephone: [phone]
Facsimile:
[phone]
Attorneys for Defendant
MILLENNIAL MEDIA, INC.

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/s/ Shawn E. McDonald
Foley & Lardner LLP
MATTHEW B. LOWRIE (Pro Hac Vice)
[e-mail]
111 Huntington Avenue, Suite 2600
Boston, MA 02119-7610
Telephone: [phone]
Facsimile:
617.342.4001
Foley & Lardner LLP
SHAWN E. MCDONALD (CSB NO. 237580)
[e-mail]
JUSTIN E. GRAY (Pro Hac Vice)
[e-mail]
3579 Valley Centre Drive, Suite 300
San Diego, CA 92130
Telephone: [phone]
Facsimile:
858.792.6773
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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)

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/s/ William A. Meunier
William A. Meunier (Pro Hac Vice)
[e-mail]
GOODWIN PROCTER LLP
Exchange Place
53 State Street
Boston, MA 02109
Telephone: [phone]
Facsimile:
[phone]

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Kurt M. Kjelland
[e-mail]
GOODWIN PROCTER LLP
4365 Executive Drive
Third Floor
San Diego, CA 92121
Telephone: [phone]
Facsimile:
[phone]

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Attorneys for Defendant JUMPTAP, INC.

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/s/ David Heskel Ben-Meir
David Heskel Ben-Meir
[e-mail]
ALSTON & BIRD LLP
333 South Hope Street, 16th Floor
Los Angeles, CA 90071
Telephone: [phone]
Fax:
[phone]

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Attorney for Defendants NOKIA, INC.,
NOKIA CORPORATION, and NAVTEQ, INC.

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REPLY IN SUPPORT OF
MOTION TO TRANSFER
CASE NO. 10-CV-1757 (LAB)