Google Inc. v. Traffic Information LLC

Filing 18

Reply (REPLY OF TRAFFIC INFORMATION, LLC TO OPPOSITION BY GOOGLE INC. TO MOTION TO DISMISS OR TRANSFER) to Motion to Dismiss for Lack of Jurisdiction titled as "Motion to Dismiss for Lack of Subject Matter Jurisdiction andAlternative Motion to Change or Transfer Venue " 8 . Filed by Traffic Information LLC. (Attachments: # 1 Attachment Second Declaration of Kevin Russell, # 2 Attachment Declaration of Richard Qian, # 3 Attachment Declaration of Bruce DeKock) (Quisenberry, C.)

Robert A. Shlachter, OSB No. 911718 Email: [e-mail] Timothy S. DeJong, OSB No. 940662 Email: [e-mail] STOLL STOLL BERNE LOKTING & SHLACHTER, P.C. 209 Southwest Oak Street Portland, Oregon 97204 [phone] [phone] (facsimile) C. Dale Quisenberry, (pro hac vice application to be filed) Texas Bar No. 24005040 Email: [e-mail] John T. Polasek, (pro hac vice application to be filed) Texas Bar No. 16088590 Email: [e-mail] Jeffrey S. David, (pro hac vice application to be filed) Texas Bar No. 24053171 Email: [e-mail] POLASEK, QUISENBERRY & ERRINGTON, L.L.P. 6750 West Loop South, Suite 920 Bellaire, Texas 77401 [phone] [phone] (facsimile) Attorneys for Traffic Information, LLC

UNITED STATES DISTRICT COURT DISTRICT OF OREGON GOOGLE INC., a Delaware corporation, Plaintiff, v. TRAFFIC INFORMATION, LLC, a Texas limited liability company, Defendant. DECLARATION OF RICHARD QIAN IN SUPPORT OF TRAFFIC INFORMATION, LLC'S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION AND ALTERNATIVE MOTION TO TRANSFER VENUE Civil No.: 09-642-HU

I, Richard Qian, declare: 1. My name is Richard Qian. I am over the age of twenty-one years and am competent

to make this declaration based on my personal knowledge. I offer this declaration in support of Traffic Information, LLC's Motion To Dismiss For Lack Of Subject Matter Jurisdiction And Alternative Motion To Transfer Venue. 2. I am one of the named inventors on U.S. Patent No. 6,466,862 ("the `862 patent") and

U.S. Patent No. 6,785,606 ("the `606 patent") (collectively "the patents-in-suit"). 3. I agree to voluntarily appear in Marshall, Texas to testify before and submit to the

jurisdiction of the United States District Court for the Eastern District of Texas, Marshall Division, in connection with any present or future lawsuits in that court related to the patents-in-suit. I declare under penalty of perjury under the laws of the United States of America that the foregoing is true and correct. Executed this _16_ day of September, 2009. ______________________________ RICHARD QIAN

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DECLARATION OF RICHARD QIAN IN SUPPORT OF TRAFFIC INFORMATION, LLC'S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION AND ALTERNATIVE MOTION TO TRANSFER

CERTIFICATE OF SERVICE The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served this 18th day of September, 2009, with a copy of this document via the Court's CM/ECF system. Any other counsel of record will be served by, electronic mail, facsimile transmission and/or first class mail on this same date. /s/ C. Dale Quisenberry

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DECLARATION OF RICHARD QIAN IN SUPPORT OF TRAFFIC INFORMATION, LLC'S MOTION TO DISMISS FOR LACK OF SUBJECT MATTER JURISDICTION AND ALTERNATIVE MOTION TO TRANSFER