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`UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
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`B.E. TECHNOLOGY, LLC,
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`Plaintiff,
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`vs.
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`AMAZON DIGITAL SERVICES, INC.,
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`Defendant.
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`No.: 2:12-cv-02767-JPM-tmp
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`JURY DEMAND
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`
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`DECLARATION OF JEFFREY H. DEAN
`IN SUPPORT OF MOTION OF AMAZON DIGITAL SERVICES, INC.
`TO TRANSFER VENUE PURSUANT TO 28 U.S.C. § 1404(a)
`I, Jeffrey H. Dean, declare as follows:
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`1.
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`I am Associate General Counsel at Amazon.com, Inc. I have personal knowledge
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`of the following, and if called upon to do so, I could and would testify competently thereto.
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`2.
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`Amazon Digital Services, Inc. (“Amazon”) is a Delaware corporation with its
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`principal place of business in Seattle, Washington.
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`3.
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`I understand that in the above-captioned litigation, B.E. Technology, LLC has ac-
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`cused a number of Kindle products of infringing United States Patent Nos. 6,771,290 and
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`6,141,010.
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`4.
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`The accused Kindle products are designed and engineered in Cupertino, Califor-
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`nia. The engineers most knowledgeable about the design, development, and operation of the ac-
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`cused Kindle products work in Amazon’s facility in Cupertino, California. These employees are
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`important to Amazon’s business and their absence for significant periods of time would adverse-
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`ly affect Amazon’s operations. The technical documentation and computer source code relating
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`to the accused Kindle products are located in and accessible from Cupertino, California.
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`
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`Case 2:12-cv-02767-JPM-tmp Document 43-2 Filed 02/12/13 Page 2 of 2 PageID 352
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`5.
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`Amazon’s headquarters for its U.S. sales, finance, and marketing operations is lo-
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`cated in Seattle, Washington. Amazon employees with knowledge of these operations are also
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`based in Seattle. Amazon’s sales, financial and marketing documents are located in Seattle.
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`6.
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`Amazon has no offices in the Western District of Tennessee and maintains no
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`servers with any relevant information in the Western District of Tennessee. A parent of the
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`named Amazon defendant maintains fulfillment centers in Tennessee—but not in the Western
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`District—that handle shipments of products purchased through the www.amazon.com website. I
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`am not aware of any employees at those facilities that would have knowledge relevant to B.E.’s
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`allegations in this lawsuit. I am also not aware of any documents located at those facilities that
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`would be relevant to B.E.’s allegations.
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`I declare under penalty of perjury under the laws of the United States that the foregoing is
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`true and correct.
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`Executed on January ___, 2013, in Seattle, Washington.
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`Jeffrey H. Dean
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`- 2 -
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