Google Inc. v. Rockstar Consortium US LP et al

Filing 67

MOTION to Transfer Case or, in the Alternative to Stay filed by MobileStar Technologies LLC, Rockstar Consortium US LP. Motion Hearing set for 6/26/2014 02:00 PM in Courtroom 2, 4th Floor, Oakland before Hon. Claudia Wilken. Responses due by 5/23/2014. Replies due by 5/30/2014. (Attachments: # 1 Declaration of Joshua Budwin, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23, # 25 Exhibit 24, # 26 Exhibit 25, # 27 Exhibit 26, # 28 Exhibit 27, # 29 Exhibit 28, # 30 Exhibit 29, # 31 Exhibit 30, # 32 Exhibit 31, # 33 Exhibit 32, # 34 Exhibit 33, # 35 Exhibit 34, # 36 Exhibit 35, # 37 Declaration of William Colvin, # 38 Declaration of Brian Egan, # 39 Declaration of Erik Fako, # 40 Declaration of Mark Hearn, # 41 Declaration of Gillian Mccolgan, # 42 Declaration of Matthew Poisson, # 43 Declaration of Donald Powers, # 44 Declaration of Marilyn French-St. George, # 45 Declaration of John Veschi, # 46 Declaration of Bruce Anthony Wootton, # 47 Proposed Order)(Budwin, Joshua) (Filed on 5/9/2014)

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Courtland L. Reichman (SBN 268873)
[e-mail]
McKool Smith Hennigan, P.C.
255 Shoreline Drive Suite 510
Redwood Shores, CA 94065
[phone]
[phone] (facsimile)
Attorneys for Defendants
Rockstar Consortium US LP and
MobileStar Technologies LLC

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UNITED STATES DISTRICT COURT

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NORTHERN DISTRICT OF CALIFORNIA

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OAKLAND

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Google, Inc.

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Plaintiff,
vs.
Rockstar Consortium U.S. LP and MobileStar
Technologies LLC
Defendants.

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Case No. 13-cv-5933 (CW)
DECLARATION OF BRUCE
ANTHONY WOOTTON IN
SUPPORT OF DEFENDANTS’
ROCKSTAR CONSORTIUM US LP
AND MOBILESTAR
TECHNOLOGIES LLC’S §1404
MOTION TO TRANSFER TO THE
EASTERN DISTRICT OF TEXAS

DECLARATION OF BRUCE ANTHONY WOOTTON IN SUPPORT OF DEFENDANTS’
ROCKSTAR CONSORTIUM US LP AND MOBILESTAR TECHNOLOGIES LLC’S
§1404 MOTION TO TRANSFER TO THE EASTERN DISTRICT OF TEXAS

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McKool 988860v1

13-cv-5933-CW
Declaration of Bruce Anthony Wootton

I, Bruce Anthony Wootton, declare:
1.

I am over eighteen years of age and in all respects fully competent to make this

Declaration. I have personal knowledge of the facts, as stated herein, and all are true and correct.
1.

I was formerly an employee of Nortel Networks.

2.

I am a named inventor of U.S. Patent No. 6,128,298. I understand this patent is at

issue in litigation in the Eastern District of Texas.
3.

I am a resident of Raleigh-Durham, North Carolina and do not travel regularly to

California.
4.

I understand at least six of the parties accused of infringing the 5,838,551,

6,037,937, 6,128,298, 6,333,973, 6,463,131, 6,765,591, and 6,937,572 patents seek to transfer
the case against them to the Northern District of California.
5.

It would be more convenient for me to attend trial in the Eastern District of Texas

than to attend trial in the Northern District of California.
6.

I am willing to travel to Marshall to attend trial.

13-cv-5933-CW
Declaration of Bruce Anthony Wootton

13-cv-5933-CW
Declaration of Bruce Anthony Wootton