Rockstar Consortium US LP et al v. Google Inc

Filing 217

RESPONSE to 188 Appeal of Magistrate Judge Decision to District Court by NetStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Declaration of Justin A. Nelson, # 2 Exhibit 1 - Google's Responses to Plaintiffs' 3rd Set of Interrogatories FILED SEPARATELY UNDER SEAL, # 3 Exhibit 2 - Address of Ericsson's Headquarters, # 4 Exhibit 3 - Map showing Ericsson's Headquarters is in the EDOT, # 5 Exhibit 4 - 8/4/14 Krishnan Notice of Subpoena, # 6 Exhibit 5 - 6/5/14 Garlick Notice of Subpoena, # 7 Exhibit 6 - 6/5/14 Garlick & Markison Notice of Subpoena, # 8 Exhibit 7 - 7/22/14 Ericsson Notice of Subpoena, # 9 Exhibit 8 - 9/8/14 Fisher Notice of Subpoena, # 10 Exhibit 9 - 9/8/14 Weiss Notice of Subpoena, # 11 Exhibit 10 - Google's 2d Notice of Rule 30(b)(6) Depo to Rockstar)(Nelson, Justin)

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

ROCKSTAR CONSORTIUM US LP
AND NETSTAR TECHNOLOGIES
LLC,
Civil Action No. 2:13-cv-893

Plaintiffs,
v.

JURY TRIAL DEMANDED

GOOGLE INC.,
Defendant.

DECLARATION OF JUSTIN A. NELSON IN SUPPORT OF
PLAINTIFFS’ RESPONSE TO DEFENDANT GOOGLE’S OBJECTIONS (Dkt. 188)
TO THE MAGISTRATE’S MEMORANDUM OPINION AND ORDER (Dkt. 165)
DENYING GOOGLE’S MOTION TO TRANSFER

I, Justin A. Nelson, declare as follows:
1.

I am a partner at the law firm of Susman Godfrey L.L.P. and I am counsel of

record for Plaintiffs Rockstar Consortium US LP and NetStar Technologies LLC (collectively
“Plaintiffs”) in this action.

I submit this declaration in support of Plaintiffs’ Response to

Defendant Google’s Objections (Dkt. 188) to the Magistrate’s Memorandum Opinion and Order
(Dkt. 165) Denying Google’s Motion to Transfer.
2.

Filed separately under seal as Exhibit 1 is a true and correct copy of Defendant

Google Inc.’s Responses to Plaintiffs’ Third Set of Interrogatories dated August 18, 2014.
3.

Attached as Exhibit 2 is a true and correct copy of a printout of the address of the

Ericsson North American headquarters as reflected on its website.

3377937v1/013149

4.

Attached as Exhibit 3 is a true and correct copy of a printout from Google Maps

showing the location of Ericsson’s headquarters along with an illustration of the border of the
Eastern District of Texas and a circle around Ericsson’s location demonstrating that its
headquarters are located within the Eastern District of Texas.
5.

Attached as Exhibit 4 is a true and correct copy of a Notice of a Subpoena served

on Raj Krishnan dated August 4, 2014.
6.

Attached as Exhibit 5 is a true and correct copy of a Notice of a Subpoena served

on Bruce E. Garlick dated June 5, 2014
7.

Attached as Exhibit 6 is a true and correct copy of a Notice of a Subpoena served

on Garlick & Markison dated June 5, 2014
8.

Attached as Exhibit 7 is a true and correct copy of a Notice of a Subpoena served

on Ericsson dated July 22, 2014
9.

Attached as Exhibit 8 is a true and correct copy of a Notice of a Subpoena served

on Art Fisher dated September 8, 2014
10.

Attached as Exhibit 9 is a true and correct copy of a Notice of a Subpoena served

on Richard Weiss dated September 8, 2014
11.

Attached as Exhibit 10 is a true and correct copy of Defendant Google Inc.’s

Second Notice of Rule 30(b)(6) Deposition to Plaintiff Rockstar Consortium US LP dated
September 30, 2014.
I declare under penalty of jury under the laws of the United States that the foregoing is
true and correct.
Dated this 23rd day of October, 2014, in Seattle, Washington.
/s/ Justin A. Nelson
Justin A. Nelson
3377937v1/013149

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