API Technologies, LLC v. Facebook, Inc. et al

Filing 183

RESPONSE to Motion re 174 MOTION to Change Venue Motion to Transfer Venue to the Northern District of California filed by API Technologies, LLC. (Attachments: # 1 Affidavit Wiley Declaration, # 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 Affidavit Spangenberg Declaration, # 37 Affidavit Spangler Declaration, # 38 Affidavit Hepburn Declaration)(Wiley, Elizabeth)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION API TECHNOLOGIES, LLC Plaintiff, v. FACEBOOK, INC., ET AL, Defendants. DECLARATION OF DEBERA W. HEPBURN My name is Debera W. Hepburn, and I reside at 2327 Round Mountain Circle, Lewisville, Texas. I am the Manager of Clear with Computers, LLC (CwC). The facts recited below regarding CwC's corporate status, place of business, and corporate parent are true and correct and if called upon testify I would truthfully testify thereto based on my personal knowledge as Manager for CwC. 1. CwC is a Texas limited liability company, with its principal office in Marshall, Civil Action No. 2:09-CV-00147 JURY TRIAL DEMANDED

Texas. Documents concerning CwC's corporate status and its business operations are, therefore, located in CwC's Marshall office. 2. CwC's parent company is TechDev Holdings, LLC. I have personal knowledge

that TechDev Holdings, LLC also has its principal office in Marshall, Texas because I also serve as Vice President - Business Development of TechDev Holdings, LLC. I declare under penalty of perjury that the above information is true and correct. Executed this 3rd day of June, 2010, at Lewisville, Texas.

/s/ Debera W. Hepburn