Pragmatus AV, LLC v. Facebook, Inc.
Memorandum in Support re 10 MOTION to Dismiss or, in the Alternative, for a More Definite Statement filed by Facebook, Inc.. (Attachments: # 1 Declaration of Justin P.D. Wilcox, # 2 Exhibit A to the Wilcox Declaration)(Wilcox, Justin)
IN THE UNITED STATES DISTRICT COURT FOR THE
EASTERN DISTRICT OF VIRGINIA
PRAGMATUS AV, LLC,
Civil Action No. 2:10-cv-00560-HCM/FBS
DECLARATION OF JUSTIN P.D. WILCOX IN SUPPORT OF DEFENDANT
FACEBOOK, INC.’S RULE 12(b)(6) MOTION TO DISMISS OR, IN THE
ALTERNATIVE, FOR A MORE DEFINITE STATEMENT
I, Justin P.D. Wilcox, hereby declare and state as follows:
1. I am an attorney licensed to practice in the Commonwealth of Virginia, where I
am an associate at the law firm of Cooley LLP, counsel in the above-captioned
matter for Defendant Facebook, Inc. (“Facebook”). This declaration is based on
my own personal knowledge. If called upon to testify, I could and would testify
2. Attached as Exhibit A is a true and correct copy of an Order Granting Motion to
Dismiss in Quito Enterprises, LLC v. Netflix, Inc., Case No. 08-23543-CIV (S.D.
Fla.), dated August 4, 2009.
I declare under penalty of perjury under the laws of the United States of America that the
foregoing is true and correct and that this declaration was executed by me on this 21st day of
January, 2011 at Reston, Virginia.
/s/ Justin P.D. Wilcox
Justin P.D. Wilcox
CERTIFICATE OF SERVICE
I certify that on the 21st day of January, 2011, I will electronically file the foregoing
DECLARATION OF JUSTIN P.D. WILCOX IN SUPPORT OF DEFENDANT FACEBOOK,
INC.’S RULE 12(b)(6) MOTION TO DISMISS OR, IN THE ALTERNATIVE, FOR A MORE
DEFINITE STATEMENT with the Clerk of Court using the CM/ECF system, which will then
send a notification of such filing (NEF) to the following:
Mark W. Wasserman (VSB #22638)
Matthew R. Sheldon (VSB #41892)
Counsel for Plaintiff, Pragmatus AV, LLC
REED SMITH LLP
3110 Fairview Park Drive
Falls Church, Virginia 22042
Telephone: (703) 641-4229
Facsimile: (703) 641-4340
/s/ Justin P.D. Wilcox
Justin P.D. Wilcox (Va. Bar No. 66067)
One Freedom Square, Reston Town Center
11951 Freedom Drive
Reston, VA 20190-5656
Attorneys for Facebook, Inc.
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