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

Filing 78

SUR-REPLY to Reply to Response to Motion re 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)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)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) Plaintiff's Sur-Reply in Support of its Opposition to Defendants' Motion to Transfer Venue to the Northern District of California filed by Wireless Recognition Technologies LLC. (Attachments: # 1 Exhibit T - Declaration of Bradley J. Botsch)(Davis, William)

EXHIBIT T

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
WIRELESS RECOGNITION
TECHNOLOGIES LLC,
Plaintiff,
v.
A9.COM, INC.,
AMAZON.COM, INC.,
GOOGLE, INC.,
NOKIA, INC.
and
RICOH INNOVATIONS, INC.
Defendants.

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C.A. No. 2:10-cv-00364-TJW-CE

JURY TRIAL DEMANDED

DECLARATION OF BRADLEY J. BOTSCH
IN SUPPORT OF PLAINTIFF’S OPPOSITION
TO DEFENDANT’S MOTION TO TRANSFER VENUE

I, Bradley J. Botsch, hereby declare and state as follows:

1.

I am authorized by Wireless Recognition Technologies LLC (“WRT”) and Acacia

Research Group, LLC (“ARG”) to submit this Declaration, for the above case, in support of
WRT’s opposition to Defendants’ Motion to Transfer Venue to the Northern District of
California Under 28 USC § 1404(a). Unless otherwise stated, I have personal knowledge of the
facts set forth herein.

2.

I am an employee of Acacia Research Group, LLC (“ARG”), with the title of Vice

President. I am listed at the following Internet web address for ARG:
http://acaciatechnologies.com/aboutus_mgmtbizdev.htm.

3.

ARG, the successor of Acacia Patent Acquisition LLC, is a Texas limited liability

company.

4.

ARG is also the parent entity of WRT, owning WRT in its entirety.

5.

I am also a Vice President of ARG, in charge of licensing and litigation of any patent

portfolios owned by WRT.

6.

ARG has its headquarters at 6136 Frisco Square Blvd., Suite 385, Frisco, TX 75034. The

contact address is provided at the following Internet web address for ARG:
http://acaciatechnologies.com/contact.htm.

7.

To my knowledge, the following individuals work full-time at ARG’s above headquarters

in Frisco, Texas, with their respective roles being provided in parentheses following their names:
Dooyong Lee (CEO), Marvin Key (Senior Vice President), Robert Rauker (Vice President of
Business Development), Phil Mitchell (Vice President of Engineering), Fahim Aftab (Vice
President of Engineering), Tisha Stender (Vice President of Licensing), Annie LeBlanc
(Attorney), Christin Johnston (Executive Assistant to CEO), Skyler Mejia (Receptionist).

8.

ARG provides offices and support to legal entities that it owns. One such company

receiving offices and support is WRT.