Google Inc. v. Rockstar Consortium US LP et al

Filing 78

REPLY (re 67 MOTION to Transfer Case or, in the Alternative to Stay ) filed byMobileStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Declaration (Supplemental) of Joshua Budwin, # 2 Exhibit 36, # 3 Exhibit 37, # 4 Exhibit 38, # 5 Exhibit 39, # 6 Exhibit 40, # 7 Exhibit 41, # 8 Exhibit 42, # 9 Exhibit 43, # 10 Declaration (Supplemental) of Donald Powers, # 11 Declaration (Supplemental) of John Veschi)(Budwin, Joshua) (Filed on 5/30/2014)

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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,

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

SUPPLEMENTAL DECLARATION OF JOSHUA W. BUDWIN 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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13-cv-5933-CW
Supplemental Declaration of Joshua Budwin

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I, Joshua W. Budwin, declare:

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Plaintiffs Rockstar Consortium US LP and Mobilestar Technologies LLC. (collectively “Rockstar”)
in the above-entitled action. I am duly licensed to practice law in the State of Texas. I make this
declaration based on my personal knowledge, the record in this action, and matters of public record,
and if called upon as a witness, I could and would testify competently as to the matters set forth
below.

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/article/2011/07/02/us-dealtalk-nortel-google-idUSTRE76104L201.
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/magazine/content/10_44/b4201043146825.htm.
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7.

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Exhibit 41 is a true and correct copy of an article entitled, “Apple and Google Call

Ceasefire in Ongoing Patent Legal War,” dated May 17, 2014 and located at http://mashable.com
/2014/05/17/apple-google-end-patent-war/.

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Exhibit 40 is a true and correct copy of a chart entitled, “Rockstar Corporate

Structure,” dated April 2014.

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Exhibit 39 is a true and correct copy of an article entitled, “The Tax Haven That’s

Saving Google Billions,” dated October 21, 2010 and located at http://www.businessweek.com

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Exhibit 38 is a true and correct copy of an article entitled, “Dealtalk: Google bid ‘pi’

for Nortel patents and lost,” dated July 1, 2011 and located at http://www.reuters.com

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Exhibit 37 is a true and correct copy of the EDTX Docket sheet for Rockstar, et al. v.

Samsung, et al., Case No. 2:13-cv-00900-JRG, as of May 29, 2014.

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Exhibit 36 is a true and correct copy of Defendants’ Reply in Rockstar, et al. v.

Samsung, et al., 2:13-cv-00900, Dkt No. 66 (E.D. Tex. Apr. 25, 2014).

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I am an attorney with the law firm of McKool Smith P.C., counsel of record for

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Exhibit 42 is a true and correct copy of excerpts from Google’s Motion in

Contentguard Holdings, Inc. v. Google, Inc., No. 2:14-cv-00061, Dkt #38 (E.D. Tex., April 16,
2014).
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Exhibit 43 is a true and correct copy of the LinkedIn web page of Michael Dunleavy.
-213-cv-5933-CW
Supplemental Declaration of Joshua Budwin

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I declare under penalty of perjury under the laws of the State of Texas that the foregoing is
true and correct, and that this declaration was executed on May 30, 2014, at Austin, Texas.

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/s/ Joshua W. Budwin
Joshua W. Budwin

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-313-cv-5933-CW
Supplemental Declaration of Joshua Budwin