Motorola Mobility, Inc. v. Microsoft Corporation

Filing 74

RESPONSE in Opposition re #62 Defendant's MOTION to Change Venue Defendant's Motion to Transfer This Action to the Western District of Washington and Accompanying Memorandum of Law filed by Motorola Mobility, Inc.. (Attachments: #1 Exhibit, #2 Exhibit, #3 Exhibit, #4 Exhibit, #5 Exhibit, #6 Exhibit, #7 Exhibit, #8 Exhibit, #9 Exhibit, #10 Exhibit, #11 Exhibit, #12 Exhibit, #13 Exhibit, #14 Exhibit, #15 Exhibit, #16 Exhibit, #17 Exhibit, #18 Exhibit, #19 Exhibit, #20 Exhibit, #21 Exhibit, #22 Exhibit, #23 Exhibit, #24 Exhibit, #25 Exhibit, #26 Exhibit, #27 Exhibit, #28 Affidavit, #29 Affidavit, #30 Affidavit)(Giuliano, Douglas)

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA
Case No. 1:10-24063-CIV-MORENO

MOTOROLA MOBILITY, INC.,

)
)

i

)

Plaintiff / Counterclaim Defendant,

)
)
)

v.

MICROSOFT CORPORATION,
Defendant / Counterclaim Plaintiff.

)
)
)
)

------------------------------)
DECLARATION OF JAMES CONROY IN OPPOSITION TO DEFENDANT'S MOTION
TO TRANSFER VENUE TO THE WESTERN DISTRICT OF WASHINGTON

1.

I am a Senior Program Manager at the Plantation, Florida location of Motorola

Mobility, Inc. ("Motorola").

I have been employed by Motorola at the Plantation location for

over seven years -- since November 2003 -- and with Motorola for a total of 19 years at other
locations.
2.

I was the Program Manager for the il iDEN Android-based phone from

conception through retail launch of the product. I led the planning activities for the product, ran
the core team meetings, led issue resolution and interfaced with the customer for field trials. My
role included coordinating the logistics of tying hardware and software together, as well as
bringing the product to market. I also monitored resource allocations for the project to ensure
the program was appropriately staffed. I understand that Microsoft has accused the il iDEN
phone of infringing five of its patents. Specifically, I have been informed that Microsoft has
accused the i 1 of infringing two patents related to gesture recognition on a touchscreen, two
patents related to synchronization of data with another system or device, and one patent related
to a hardware timer.
3.

I was asked to submit this declaration in opposition to a motion I understand

Microsoft has filed. I am personally familiar with and knowledgeable about the facts stated in
this declaration and could testify competently about the statements I make in this declaration.
4.

The il iDEN phone was developed at Plantation over a period of 18 months,

from January 2009 through June 20 I O. All of the lead Motorola employees for the product and
most of the rest of the employees who worked on the product were located in Plantation. The
bulk of the work on the product was carried out in Plantation and included software design work,
electrical work, mechanical work, media decision-making, and marketing, including direction of

1

the user-interface design. This work included the design of the accused gesture recognition and
data synchronization features on the i 1 phone.
5.

Some of the SW work on the product was carried out in Nanjing and Beijing,

China. The mechanical industrial design work on the product was carried out in Chicago; and a
small amount of work on third-party applications was carried out in San Diego. At Plantation, I
oversaw the integration of work on the i1 phone carried out at other locations.
6.

Work on the il iDEN phone was a priority for the Plantation location. Plantation

was the logical choice as the location for development of this product because the Motorola
employees with expertise in developing iDEN phones are located in Plantation. The technology
for the i1 IDEN phone grew out of this expertise.
7.

At peak, approximately 161 people were working on i 1 worldwide. Plantation

had 74 people working on the i1 iDEN phone. Of these 74, 39 were software engineers, 14 were
electrical engineers, 14 were mechanical engineers and the balance were marketing, quality and
management. The remainder of the resources were 74 in China, 9 in Brazil, and 4 in Singapore.
8.

The electrical design team consisted of 14 people -- all located in Plantation.

9.

The mechanical design team consisted of 14 people located in Plantation, with 4

in Brazil.
10.

The marketing team consisted of 4 people -- all located in Plantation.

11.

Numerous documents relating to the design, development, testing, and marketing

of the il phone are located at the Plantation facility.

2

I declare under penalty of perjury that the foregoing is true and correct.
Executed on June _'

2011.

3