Eolas Technologies Incorporated v. Adobe Systems Incorporated et al

Filing 216

NOTICE by JPMorgan Chase & Co. re 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) MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. 1404(a) MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. 1404(a) MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. 1404(a) MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. 1404(a) MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. 1404(a) MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. 1404(a) MOTION to Change Venue to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. 1404(a) Notice of Joinder (Yarbrough, Herbert)

IN THE UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION Eolas Technologies Incorporated, § § Plaintiff, § § vs. § § Adobe Systems Inc., Amazon.com, Inc., § Apple Inc., Argosy Publishing, Inc., § Blockbuster Inc., CDW Corp., § Citigroup Inc., eBay Inc., Frito-Lay, Inc., § The Go Daddy Group, Inc., Google Inc., § J.C. Penney Company, Inc., JPMorgan § Chase & Co., New Frontier Media , Inc., § Office Depot, Inc., Perot Systems Corp., § Playboy Enterprises International, Inc., § Rent-A-Center, Inc., Staples, Inc., Sun § Microsystems Inc., Texas Instruments § Inc., Yahoo! Inc., and YouTube, LLC § § Defendants §

Civil Action No. 6:09-cv-446

Defendant JP Morgan Chase & Co.'s Joinder in Motion to Transfer to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. § 1404(a) Defendant, JP Morgan Chase & Co. ("JP Morgan"), hereby joins Defendants Adobe Systems, Inc., Amazon.com, Inc., Apple Inc., Blockbuster Inc., Ebay, Inc., The Go Daddy Group, Inc., Google, Inc., New Frontier Media Inc., Playboy Enterprises International, Inc., Sun Microsystems Inc., and YouTube, LLC in their Motion for Transfer to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. §1404(a). JP Morgan is in agreement that the transfer of this case to the Northern District of California is appropriate because the infringement allegations in Plaintiff's Complaint are directed to the specific products of Northern California Defendants including

Apple, Sun, Adobe and Google. Additionally, numerous witnesses relevant to the claims and defenses are located in the Northern District of California. Therefore, JP Morgan joins this Motion to Transfer to the U.S. District Court for the Northern District of California Pursuant to 28 U.S.C. §1404(a).

Dated: February 11, 2010

Respectfully submitted, /s/ Trey Yarbrough Trey Yarbrough Bar No. 22133500 Debby Gunter Bar No. 24012752 Yarbrough Wilcox, PLLC 100 E. Ferguson St., Ste. 1015 Tyler, TX 75702 Phone: [phone] Fax: [phone] [e-mail] Joel Freed VA Bar No. 06555 McDermott Will & Emery 600 13th St. N.W. Washington, D.C. 20005 [phone] Fax: [phone] [e-mail] Attorneys for Defendant, JP Morgan Chase & Co. Certificate of Service

The undersigned hereby certifies that all counsel of record who are deemed to have consented to electronic service are being served with a copy of this document via the Court's CM/ECF system per Local Rule CV-5(a)(3) on February 11, 2010. All other counsel of record will be served via facsimile or first class mail.

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/s/ Trey Yarbrough Trey Yarbrough

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