Uniloc USA, Inc. et al v. NATIONAL INSTRUMENTS CORP. et al

Filing 113

Joint MOTION to Change Venue Under 28 U.S.C. § 1404(a) by Adobe Systems Inc., Alladin Knowledge Systems Ltd., Alladin Knowledge Systems, Inc., CA, Inc., NATIONAL INSTRUMENTS CORP., Onyx Graphics, Inc., Pinnacle Systems, Inc., Safenet, Inc., Sonic Solutions, Symantec Corp.. (Attachments: # 1 Exhibit 1-Sony motion to transfer, # 2 Exhibit 2-Sony reply ISO motion to transfer, # 3 Exhibit 3-Sony reply to sur-reply ISO motion to transfer, # 4 Exhibit 4-Uniloc complaint (USDC D. RI), # 5 Exhibit 5-Notice of dismissal of Aladdin Knowledge Systems Inc., # 6 Exhibit 6-National Instruments Corporation declaration, # 7 Exhibit 7-Adobe Systems Incorporated declaration, # 8 Exhibit 8-SafeNet, Inc. declaration, # 9 Exhibit 9-CA, Inc. declaration, # 10 Exhibit 10-Pinnacle Systems, Inc. declaration, # 11 Exhibit 11-Sonic Solutions declaration, # 12 Exhibit 12-Onyx Graphics, Inc. declaration, # 13 Exhibit 13-Symantic Corp. declaration, # 14 Exhibit 14-Aladdin Knowledge Systems, Inc. and Aladdin Knowledge Systems, Ltd. declaration, # 15 Text of Proposed Order)(Healey, David)

Uniloc USA, Inc. et al v. NATIONAL INSTRUMENTS CORP. et al

Doc. 113 Att. 7

EXHIBIT 7

Dockets.Justia.com

UNITED STATES DISTRICT COURT FOR THE EASTERN DISTRICT OF TEXAS TYLER DIVISION
UNILOC USA, INC., ET AL.

Plaintiffs,
Civil Action No. 6:10-cv-472-LED
v.

JURY TRIL DEMANDED
NATIONAL INSTRUMENTS CORP., ET AL.,
Defendants.

DECLARATION OF JOSEPH NEMETH IN SUPPORT OF ADOBE SYSTEMS INCORPORATED'S MOTION TO TRANSFER
I, Joseph Nemeth, declare as follows:
1. I am a Vice President Senior Financial Executive of Adobe Systems Incorporated

("Adobe"). I submit this Declaration in support of defendants' Motion to Transfer Venue Under

Rule 28 U.S.c. § 1404(a). I have personal knowledge of the facts set forth in this Declaration
unless otherwise stated.
2. Adobe is a company organized and existing under the laws of Delaware with its

principal place of business located in San Jose, California. Adobe is a publicly held software
company.
3. I am informed that the Plaintiffs Uniloc USA, Inc. and Uniloc Singapore Private

Limited (collectively, "Uniloc") allege that Adobe directly and/or indirectly infringes U.S. Patent
No. 5,490,216 "by, among other things, making, using, offering for sale, selling and/or importing a system, device and/or method for reducing software piracy, reducing casual copying and/or
reducing the unauthorized use of software, including without limitation Adobe's Acrobat and Creative Suite products that permit customers to activate and/or register software."
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4. Adobe has offered for sale and has sold the accused Acrobat and Creative Suite
products in Rhode Island.

I declare under penalty of perjury of the laws of the United States and Texas that the
foregoing is true and correct.

Dated: March 17, 2011

~~
Jose emeth

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