Rockstar Consortium US LP et al v. Google Inc

Filing 36

REPLY to Response to Motion re 18 MOTION to Change Venue filed by Google Inc. (Attachments: # 1 Declaration of Sam Stake, # 2 Exhibit 45, # 3 Exhibit 46, # 4 Second Declaration of Abeer Dubey)(Mann, James)

IN THE UNITED STATES DISTRICT COURT
FOR THE EASTERN DISTRICT OF TEXAS
MARSHALL DIVISION
ROCKSTAR CONSORTIUM US LP AND
NETSTAR TECHNOLOGIES LLC,
Plaintiffs,
v.
GOOGLE INC.
Defendant.

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Civil Action No. 13-cv-00893-RG
JURY TRIAL DEMANDED

DECLARATION OF SAM STAKE
I, Sam Stake, declare:
1.

I am an attorney with the law firm of Quinn Emanuel Urquhart & Sullivan, LLP,

counsel to Google Inc. in this action. I have personal knowledge of the facts set forth in this
declaration, and if called upon to do so, could and would testify competently thereto.
2.

Attached as Exhibit 45 is a true and correct copy of “Rockstar CEO Says He

Would Not Bet Against Further Suits To Follow Those Issued Last Week,” in Intellectual Asset
Management Magazine, dated November 4, 2013, accessible at http://www.iammagazine.com/blog/detail.aspx?g=d258542c-dbfc-4977-9fa7-9f885d95ff91 (last accessed on
March 9, 2014).
3.

Attached as Exhibit 46 is a true and correct copy of “U.S. District Courts—

Median Time Intervals From Filing to Disposition of Civil Cases Terminated, by District and
Method of Disposition, During the 12-Month Period Ending March 31, 2013,” accessible at the
website of the Administrative Office of the U.S. Courts on behalf of the Federal Judiciary, at

01980.00010/5806352.1 01980.00010/5681296.1

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http://www.uscourts.gov/Viewer.aspx?doc=/uscourts/Statistics/FederalJudicialCaseloadStatistics
/2013/tables/C05Mar13.pdf (last accessed on March 9, 2014).
I declare under penalty of perjury that the foregoing statements are true and correct to the
best of my knowledge.

Dated: March 10, 2014

Respectfully submitted,
By: /s/ Sam Stake
Sam Stake

01980.00010/5806352.1 01980.00010/5681296.1

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