Rockstar Consortium US LP et al v. Google Inc

Filing 33

RESPONSE to Motion re 18 MOTION to Change Venue filed by NetStar Technologies LLC, Rockstar Consortium US LP. (Attachments: # 1 Declaration of Donald Powers, # 2 Declaration of Mark Hearn, # 3 Declaration of Kristin Malone, # 4 Exhibit 1 to Decl. of K. Malone, # 5 Exhibit 2 to Decl. of K. Malone, # 6 Exhibit 3 to Decl. of K. Malone, # 7 Exhibit 4 to Decl. of K. Malone, # 8 Exhibit 5 to Decl. of K. Malone, # 9 Exhibit 6 to Decl. of K. Malone, # 10 Exhibit 7 to Decl. of K. Malone, # 11 Exhibit 8 to Decl. of K. Malone, # 12 Exhibit 9 to Decl. of K. Malone, # 13 Exhibit 10 to Decl. of K. Malone, # 14 Exhibit 11 to Decl. of K. Malone, # 15 Exhibit 12 to Decl. of K. Malone, # 16 Exhibit 13 to Decl. of K. Malone, # 17 Exhibit 14 to Decl. of K. Malone, # 18 Exhibit 15 to Decl. of K. Malone, # 19 Text of Proposed Order)(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

Plaintiff,
v.

JURY TRIAL DEMANDED

GOOGLE INC.,
Defendant.

DECLARATION OF KRISTIN MALONE IN SUPPORT OF PLAINTIFFS’
RESPONSE TO GOOGLE’S MOTION TO TRANSFER
I, Kristin Malone, declare as follows:
1.

I am a member in good standing of the Washington State Bar.

2.

I am an attorney at the law firm Susman Godfrey LLP and I am one of the

attorneys serving as counsel for Plaintiffs Rockstar Consortium US LP and NetStar Technologies
LLC (collectively “Rockstar”) in this action. I submit this declaration in support of Plaintiffs’
Response to Google’s Motion to Transfer, which is filed herewith.
3.

Attached hereto as Exhibit 1 is a true and correct copy of the U.S. Patent and

Trademark Office’s Press Release 13-39, dated December 11, 2013, titled “U.S. Secretary of
Commerce Penny Pritzker Names Michelle K. Lee as Next Deputy Director of the U.S. Patent
and Trademark Office,” which notes that Ms. Lee’s present position is in Alexandria, Virginia.
4.

Attached hereto as Exhibit 2 is a true and correct copy of an internet article

published in the Intellectual Asset Management Magazine, Issue 50 November/December 2011,
1

titled “The players,” which notes on page 38 that Michelle Lee was the head of patent strategy at
Google at the time of the Nortel auction.
5.

Attached hereto as Exhibit 3 is a true and correct copy of an internet screen shot;

from a Google web page, titled “Inside Google Bangalore.”
6.

Attached hereto as Exhibit 4 is a true and correct copy of an internet article titled

“Google’s Colossus Makes Search Real-Time by Dumping MapReduce,” dated September 11,
2010.
7.

Attached hereto as Exhibit 5 is a true and correct copy of an internet screen shot,

from a Google web page located at https://sites.google.com/site/newyorkengineeringopenhouse/
speaker-bios-1, titled “Speaker Bios.”
8.

Attached hereto as Exhibit 6 is a true and correct copy of an internet screen shot,

from a Google web page, titled “Frequently asked Questions” regarding Google New York.
9.

Attached hereto as Exhibit 7 is a true and correct copy of an internet screen shot,

from a Google web page, titled “Inside Google New York.”
10.

Attached hereto as Exhibit 8 is a true and correct copy of an internet screen shot,

from a Google job-postings web page, titled “Operations Engineer.”
11.

Attached hereto as Exhibit 9 is a true and correct copy of an internet screen shot,

from a Google web page, titled “Data center locations.”
12.

Attached hereto as Exhibit 10 is a true and correct copy of an AOL press release

titled “AOL and Google Renew and Expand Global Partnership,” dated September 2, 2010.
13.

Attached hereto as Exhibit 11 is a true and correct copy of an IAC press release

titled “IAC Extends Agreement with Google,” dated April 11, 2011.

2

CERTIFICATE OF SERVICE
I hereby certify that all counsel of record, who are deemed to have consented to
electronic service are being served this 20th day of February, 2014 with a copy of this document
via the Court’s CM/ECF system per Local Rule CD-5(a)(3).

/s/ Justin A. Nelson