Wireless Recognition Technologies LLC v. A9.com, Inc. et al

Filing 62

Opposed MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. § 1404(a) by A9.com, Inc., Amazon.com, Inc., Google, Inc.,, Nokia, Inc., Ricoh Innovations, Inc.. (Attachments: # 1 Exhibit A, # 2 Exhibit B, # 3 Exhibit C, # 4 Exhibit D, # 5 Exhibit E, # 6 Exhibit F, # 7 Exhibit G, # 8 Exhibit H, # 9 Exhibit I, # 10 Exhibit J, # 11 Exhibit K, # 12 Exhibit L, # 13 Exhibit M, # 14 Exhibit N, # 15 Exhibit O, # 16 Text of Proposed Order)(Smith, Michael)

Wireless Recognition Technologies LLC v. A9.com, Inc. et al

Doc. 62 Att. 2

EXHIBIT B

Dockets.Justia.com

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS MARSHALL DIVISION

WIRELESS RECOGNITION TECHNOLOGIES LLC, Plaintiff, vs. A9.COM, INC., AMAZON.COM, INC., GOOGLE INC., NOKIA, INC., and RICOH INNOVATIONS, INC., Defendants.

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CIVIL NO. 2:10-CV-00364-TJW-CE

JURY TRIAL DEMAND

DECLARATION OF DAVID PETROU IN SUPPORT OF DEFENDANTS' MOTION TO TRANSFER

I, David Petrou, declare: 1. I am currently employed at Google Inc., where I have been employed

continuously since 2006. I provide this declaration in support of Defendants' joint motion to transfer this case from the Eastern District of Texas to the Northern District of California. Unless otherwise indicated below, the statements in this declaration are based upon my personal knowledge and investigation or upon corporate records maintained by Google in the ordinary course of business. I am over 18 years of age and if called upon to testify in this matter, would affirm the truthfulness of each statement. 2. I understand that Wireless Recognition Technologies, LLC has accused two

Google applications, Google Goggles and Google Shopper, of patent infringement. 3. Google is a Delaware corporation with its headquarters and principal place of

business in Mountain View, California, which is located in the Northern District of California. 4. My position at Google is Staff Engineer, and I am the Technical Lead Manager

for the Google Goggles application, which is one of the two Google applications accused of infringement in this action. 5. Google Goggles is an application that was developed at Google. The Google

employees responsible for the development of the software for that application include: Matt Casey and Ashkot Popat, who are employed in and reside near Google's Mountain View, California office; Neven Hartnut, who is employed in and resides near Google's Santa Monica, California office; and myself. I am employed in and reside near Google's New York, New York office. These same employees are also responsible for the continued development of the Google Goggles product. 6. I unaware of any individuals that reside or work in Texas that were responsible

for the development of the Google Goggles application or that are knowledgeable about the development of that application.

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