The Facebook, Inc. v. Connectu, Inc et al

Filing 27

Declaration of Winston Williams in Support of Motion to Dismiss for Lack of Personal Jurisdiction Pursuant to Fed. R. Civ. P. 12(B)(2( 23 ) filed by Winston Williams. (Mosko, Scott) (Filed on 3/21/2007) Modified on 3/22/2007 (bw, COURT STAFF).

The Facebook, Inc. v. Connectu, LLC et al

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Case 5:07-cv-01389-RS

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Scott R. Mosko (State Bar No. 106070) FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, L.L.P. Stanford Research Park 3300 Hillview Avenue Palo Alto, California 94304 Telephone: [phone] Facsimile: [phone] Attorneys for Defendant Winston Williams

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF CALIFORNIA

FACEBOOK, INC. Plaintiff, v. CONNECTU LLC (now known as CONNECTU, INC.), PACIFIC NORTHWEST SOFTWARE, INC., WINSTON WILLIAMS, AND DOES 1-25, Defendants.

CASE NO. C 07-01389 RS DECLARATION OF WINSTON WILLIAMS IN SUPPORT OF MOTION TO DISMISS FOR LACK OF PERSONAL JURISDICTION PURSUANT TO FED. R. CIV. P. 12(B)(2) Date: Time: Courtroom: Judge: May 2, 2007 9:30 a.m. 4 Hon. Richard Seeborg

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DECLARATION OF WINSTON WILLIAMS CASE NO. C 07-01389 RS

Dockets.Justia.com

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I, WINSTON WILLIAMS, declare 1. 2. 3. Washington; 4. 5. I do not maintain a registered agent for service in California; I do not own, lease, possess or maintain any real or personal property in I am a resident and citizen of the state of Washington; My domicile is Seattle, Washington; I received a copy of the summons and the Amended Complaint in

California, and have not owned, leased, possessed or maintained any real or personal property in California; 6. I do not own, lease or maintain an office, residence or place of business in

California, and I have not owned, leased or maintained an office, residence or place of business in California; 7. 8. 9. I have never had an authorized agent or representative in California; I do not and have not paid taxes of any kind in the state of California; I do not maintain any bank or savings and loan accounts in California and

have not maintained any bank or savings and loan accounts in California; 10. 11. I have never performed any service or sold any goods in California; I have not and do not derive substantial revenue from goods used or

consumed in California or services rendered in California; 12. of California; 13. 14. 15. California; ///
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I do not engage in a business and have not engaged in business in the state

I have never recruited employees in California; I have never signed any contracts in California; I do not presently nor have I ever maintained a telephone listing in

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DECLARATION OF WINSTON WILLIAMS CASE NO. C 07-01389 RS

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16.

Any activity that concerned email addresses available on thefacebook.com

website in which I was involved was done pursuant to my employment with Pacific Northwest Software, Inc.

I declare under penalty of perjury under the laws of the United States that the foregoing is true and correct and that this declaration was executed on the 21st day of March, 2007 at Seattle, Washington.

______________/s/________________ Winston Williams

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DECLARATION OF WINSTON WILLIAMS CASE NO. C 07-01389 RS