`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE DISTRICT OF DELAWARE
`
`C.A. No. 16-290-SLR
`
`JURY TRIAL DEMANDED
`
`)))))))))
`
`GODO KAISHA IP BRIDGE I,
`
`Plaintiff,
`
`v.
`
`OMNIVISION TECHNOLOGIES, INC.,
`
`Defendant.
`
`DECLARATION OF JENNIFER J. SCHMIDT IN SUPPORT OF
`DEFENDANT OMNIVISION TECHNOLOGIES, INC.’S MOTION TO
`TRANSFER VENUE TO THE NORTHERN DISTRICT OF CALIFORNIA
`
`I, Jennifer J. Schmidt, declare as follows:
`
`1.
`
`I am a partner of the law firm of Wilson Sonsini Goodrich & Rosati, Professional
`
`Corporation, attorneys for Defendant OmniVision Technologies, Inc. (“OmniVision”) in the
`
`above-captioned matter. I submit this declaration in support of OmniVision Technologies, Inc.’s
`
`motion to transfer this action to the United States District Court for the Northern District of
`
`California.
`
`2.
`
`Attached hereto as Exhibit A is a true and correct copy of Plaintiff Godo Kaisha IP
`
`Bridge 1’s company profile which is available on its website at http://ipbridge.co.jp/en/company.
`
`3.
`
`Attached hereto as Exhibit B is a true and correct copy of U.S. Patent No.
`
`6,346,745.
`
`4.
`
`Attached hereto as Exhibit C is a true and correct copy of U.S. Patent No.
`
`6,887,353.
`
`5.
`
`Collectively, U.S. Patent Nos. 6,346,745 and 6,887,353 name at least five third-
`
`party inventors located in the Northern District of California.
`
`
`
`Case 1:16-cv-00290-MN Document 12 Filed 05/16/16 Page 2 of 3 PageID #: 445
`
`6.
`
`Attached hereto as Exhibit D is a true and correct copy of the results from a Google
`
`search for flights between Tokyo, Japan and San Francisco, California conducted on May 11, 2016.
`
`7.
`
`Attached hereto as Exhibit E is a true and correct copy of the results from a Google
`
`search for flights between Tokyo, Japan and Wilmington, Delaware conducted on May 11, 2016.
`
`8.
`
`Attached hereto as Exhibit F is a true and correct copy of the results from a Google
`
`search for flights between Taipei, Taiwan and San Francisco, California conducted on May 11,
`
`2016.
`
`9.
`
`Attached hereto as Exhibit G is a true and correct copy of the results from a Google
`
`search for flights between Taipei, Taiwan and Wilmington, Delaware conducted on May 11, 2016.
`
`10.
`
`Attached hereto as Exhibit H is a true and correct copy of the results from a Google
`
`search for flights between Shanghai, China and San Francisco, California conducted on May 11,
`
`2016.
`
`11.
`
`Attached hereto as Exhibit I is a true and correct copy of the results from a Google
`
`search for flights between Shanghai, China and Wilmington, Delaware conducted on May 11,
`
`2016.
`
`12.
`
`Each of U.S. Patent Nos. 7,411,180; 8,592,880; 7,944,493; 7,728,895; and
`
`8,004,026 name inventors located in Japan.
`
`13.
`
`Attached hereto as Exhibit J is a true and correct copy of the statistical report
`
`“Federal
`
`Court
`
`Management
`
`Statistics–Profiles”
`
`which
`
`is
`
`available
`
`at
`
`http://www.uscourts.gov/statistics-reports/federal-court-management-statistics-december-2015.
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is
`
`true and correct.
`
`- 2 -
`
`
`
`Case 1:16-cv-00290-MN Document 12 Filed 05/16/16 Page 3 of 3 PageID #: 446
`
`Executed at San Francisco, California, on May 16, 2016.
`
`/s/ Jennifer J. Schmidt
`
`- 3 -
`
`
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