Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 214

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 Apple Inc.. (Attachments: # 1 Affidavit Teague I. Donahey, # 2 Exhibit 1, # 3 Exhibit 2, # 4 Exhibit 3, # 5 Exhibit 4, # 6 Exhibit 5, # 7 Exhibit 6, # 8 Exhibit 7, # 9 Exhibit 8, # 10 Exhibit 9, # 11 Exhibit 10, # 12 Exhibit 11, # 13 Exhibit 12, # 14 Exhibit 13, # 15 Exhibit 14, # 16 Exhibit 15, # 17 Exhibit 16, # 18 Exhibit 17, # 19 Exhibit 18, # 20 Exhibit 19, # 21 Exhibit 20, # 22 Exhibit 21, # 23 Exhibit 22, # 24 Exhibit 23, # 25 Exhibit 24, # 26 Exhibit 25, # 27 Exhibit 26, # 28 Exhibit 27, # 29 Exhibit 28, # 30 Exhibit 29, # 31 Exhibit 30, # 32 Exhibit 31, # 33 Exhibit 32, # 34 Exhibit 33, # 35 Exhibit 34, # 36 Exhibit 35, # 37 Exhibit 36, # 38 Exhibit 37, # 39 Exhibit 38, # 40 Exhibit 39, # 41 Exhibit 40, # 42 Exhibit 41, # 43 Exhibit 42, # 44 Exhibit 43, # 45 Exhibit 44, # 46 Exhibit 45, # 47 Exhibit 46, # 48 Exhibit 47, # 49 Exhibit 48, # 50 Exhibit 49, # 51 Exhibit 50, # 52 Exhibit 51, # 53 Exhibit 52, # 54 Exhibit 53, # 55 Exhibit 54, # 56 Exhibit 55, # 57 Exhibit 56, # 58 Exhibit 57, # 59 Exhibit 58, # 60 Exhibit 59, # 61 Exhibit 60, # 62 Exhibit 61, # 63 Exhibit 62, # 64 Exhibit 63, # 65 Exhibit 64, # 66 Exhibit 65, # 67 Exhibit 66, # 68 Exhibit 67, # 69 Exhibit 68, # 70 Exhibit 69, # 71 Exhibit 70, # 72 Exhibit 71, # 73 Exhibit 72, # 74 Exhibit 73, # 75 Exhibit 74, # 76 Exhibit 75, # 77 Affidavit Darin Adler, # 78 Exhibit A, # 79 Exhibit B, # 80 Affidavit Marc D. Callipari, # 81 Affidavit Jeetendra Kaul, # 82 Affidavit Steven Mansour, # 83 Affidavit Mark Risher, # 84 Affidavit Sean Scott, # 85 Affidavit Prasad Setty, # 86 Affidavit Jason W. Wolff, # 87 Text of Proposed Order)(Cederoth, Richard) (Additional attachment(s) added on 2/11/2010: # 88 Corrected Proposed Order) (mjc, ).

EXHIBIT 3

A b o u t Us
~llSSION

Eolas' mission is to pursue
PRODUCTS --,--

II disciplined program of r"s.earch .00 development in t",-geled areas in the fidd ofl»oinfOfl1l3tics through its wooDy-owned subsidiary.

lomas Rese..-ch LLC, leading to the creation ofinno\.m-"e l . c h n o l o g i e s ofbroad

applicability in daIa ,malysis, visualization, col1aboration and nffi\'o.-king thai mhaoc" the quality oflif. fo.- " " " ' ) ' ' ' ' ' ' ' ' Eolas ~ks to return v:We to its
sha,-ehokk,-s by cOlItlll..-ci:llizing the", tedlllologies through strategic .niaoce . ,

licensing and spin off,

Chainnan - Dr. iMichad D. Doyle

Dr. Dor!. is Eolao;' four><kr and a:rCMe<:1 of the company's , . " , . . - c b . o o de"elopmmt dfoftS. Dr. Doyle recri\·ed his PhD. in Biology from the Um-.,-s;ty of Il!toois - U r b a n a Prior to founding Eolas, Dr. Doyle sn-,"ed as Direc\o.- f o r the Cent..- for Knowledge Manag= at the UM-"-sit)' ofCalifomia - San Franciseo_ While at the UCSF Medical Cent..-, Dr. Doyle led II re",,,,-ch le= that oo'doped fUndan=tal web tedlnologies that resulted in the '90(; palmi, which enabled Web brow=-s fOf the first time 10 act as platfonns fOf fully-irn..-acm-e "",bedded applications. T{) assist the Uni\'''-sit)' of California in comm..-cializing the '906 palen!, Dr. Doyle founded Eolas and M led Eolas until Ocl~ 2007 WMn he assumed his nev.' rok as CEO ofEola, subsidiary, lomas R~",arch. LLC. 0,-. Doyle succ e ssfully gui<Ied Eolas through major litigation with Microsoft .00 the de... elopment of ",,·..-al key te<:hnologies. 0,-. Doyle', =nina! re",arch in next-generation Web applications, 3-D I»omedical \isualization, .00 mo.-phospatial genomic acti"ity mapping has kd to nev,' te<:hnologies that Iw:e g.mro
worldv.1<Ie re<:ognitioo. His transient-key Cf)'Plographic timest"",!, innovations soh'e pr~iously intraclabk probkms cr.ated b}' HIPAA.oo Sarb1llles- O x l e y regulations, .00 w,'e ban adopled in the x9.95 ANSl N3tional Standard for ~e timestamps
Chid"Executj,.-~

OfIic..- - M a r k

C. Swords

Mr. Swords joined Eolas

a< CNd"0pe,-1IIing Offic..- in J""uary, 2006, .00 kcame Chid"Ex~cutj,:e Offic..- in Cktob..- o f 2 0 0 7 . H e came to Eolas from the inl..-nationallaw firm ofBak..- & ~kKenzie, wh..-e he was a p..nn..- a n d """ed a< the practice group chair for Bak..- & )'kKenzie's Chicago oflic ~ COfJXlfate and ~,practice group. Mr. Swords joined Bale..- & McKenzie in 1992 and has s""ed a< a monb..- o f B a k . . - & McKenzie', global management Ie"",. As Bak..& McKenzie', first Chid"Knowledge Offic..-, he ,k.:eloped the firm's knowledge managemenl strategy and buih the finn's global knowledge management organization. In addition to Mr. Swords' management experieoc~ , Mr. Swords brings wirh him a broad",", of transactional skitts. H e d~'eloped a o;ophi,ticated corporate, cOUll1lefcial and complia:oce practic e in which he ad"ised U.S . .00 OOfI-U.S. dent, in ",,·..-al industries on a wide ,-",-jety ofme.-g..-s and acquisitions, join! \"~ture s, strategic .nianc e s, .00 cO!1llllefcialtr:msactions
Chid"L~gal

Offic..- - J a m e s L Stetson

Mr. Stetson joined Eolas as CNd"Legal Offic..- in J1IIIuary, 2006 from the int..-nationallaw firm ofBak..- & McKenzie, wher. he was a pann..- in Bak..- & McKenzie's Infonnation Te<:hnolo~, Practic ~ G.-oup.l\b-. Stetson joined Bak..& McKenzie in 1993 and has """ed a< the practic e group chair ofits 1nf0fl11:lti0n Te<:hnolo~s Practic e G.-oup. iMr. Sletson has practiced in the high Ie<:hnology area for 0... ..- m'~ year, and he has <Je,,'doped a broad "'"' of tran,actional skiIl,
in growing a o;ophisticated licensing and OIJ!><rurcing practic~ OPERATIONS Eolas has a proven track re<:ord of generating fundamentalle<:hnolo~s The Eolas management leam has significant experience in licensing, m..-g..-s and acquisitions, join! \"~ture s and strategic allianc ~ s: arenas that are critical a< Eolas looks 10 comm..-cialize nev,' and existing Ie<:hnologie, discussion und..- the heading entitled R e s e a r c h for a description of the that the comp:m}' currently js re",arching or <Je,,'doping through its lomas Re",,,,-ch, LLC subsidiary. By focu,sing R&D drorts 011 the wIution to vet)' specific problems in the hKlinfonnatics area. the comp1llly w:ill COlltinue to <Je,,'dop Ie<:hnologies ofbroad applicability
Ie<:hnolo~,

Ple~ "'~

Copyright '0 2006, 2007, 2008, 2009 Eolas Te<:hnologies Inc., all rights r~"""'ed Eolas ,lands for ""'Emkdded Obje<:ts Linked Across Sysl=s~ and j, al", the Gaelic word for «Knowledge" Eolas, Musart n i and -in... enled h..-e." are trademarks ofEoIas T~hnologies Inc