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. 4

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 G.D. RAMKUMAR IN SUPPORT OF DEFENDANTS' MOTION TO TRANSFER

I, G.D. Ramkumar, declare: 1. I am the Chief of Architecture, Visual Search, at A9.com, Inc. I submit this

declaration based on my personal knowledge and on information provided to me in the course of my employment. 2. A9.com, Inc. ("A9") is headquartered and maintains its principal place of business

in Palo Alto, California. The majority of A9's employees are located in Palo Alto. A9 is a wholly owned and operated subsidiary of Amazon.com, Inc. 3. I understand that Wireless Recognition Technologies, LLC has accused A9's

SnapTell application of patent infringement. I also understand that the Amazon Remembers and Price Check features of Amazon's mobile applications have also been accused of infringement. 4. The SnapTell application was originally developed by SnapTell, Inc. ("Snaptell").

I co-founded SnapTell along with Gautam Bhargava in April 2006. I served as the Chief Technology Officer (CTO), and Gautam served as the Chief Executive Officer (CEO). SnapTell's headquarters and employees (including those responsible for software development) were located in Palo Alto, California. 5. SnapTell was acquired by A9 in 2009. In connection with the acquisition, the

core development team for the SnapTell application joined A9. The employees responsible for the continued development of the SnapTell application work in A9's Palo Alto office. 6. Some of the A9 employees knowledgeable about the development and

functionality of the SnapTell application include: Gautam Bhargava (Vice President of Visual Search); Keshav Menon (Software Development Engineer); and Arnab Dhua (Software Development Engineer). These individuals all work at A9.com's Palo Alto office and live in Northern California. 7. Nearly all of the records, source code, and other materials concerning the

SnapTell application (and the former SnapTell corporation) are located in Palo Alto, California.

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