`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`
`B.E. TECHNOLOGY, L.L.C.,
`
`Civil Action No. 2:12cv2769 JPM-tmp
`
`v.
`
`FACEBOOK, INC.,
`
`Plaintiff,
`
`Defendant.
`
`Hon. Jon Phipps McCalla
`
`JURY DEMAND
`
`DECLARATION OF JEREMY JORDAN IN SUPPORT OF FACEBOOK'S MOTION
`TO TRANSFER VENUE TO THE UNITED STATES DISTRICT COURT FOR THE
`NORTHERN DISTRICT OF CALIFORNIA
`
`I, Jeremy Jordan, hereby declare:
`
`1.
`
`I am employed by Defendant Face book, Inc. as a Litigation Paralegal and provide this
`
`declaration in support of Facebook's motion to transfer this action to the United States District·
`
`Court for the N01thern District of California. I declare that the following statements are true to
`
`the best of my knowledge, information, and belief, formed after a reasonable inquiry under the
`
`circumstances. If called upon to testify, I could and would competently testify thereto.
`
`2.
`
`Facebook is a Delaware corporation with its headquarters and principal place of
`
`business in Menlo Park, California. Facebook moved to Palo Alto, California, in June2004, just
`
`months after its initial launch in February 2004. From June.2004 to its move to Menlo Park in
`.
`-
`
`2011, Facebook's headquarters and principal place of business was in Palo Alto. Both Menlo
`
`Park and Palo Alto are within the Northern District of California.
`
`3. · Facebook's management team and primary engineering facilities are located at its
`
`headquarters in Menlo Park. Nearly all of the highly proprietary information and source code
`
`
`
`Case 2:12-cv-02769-JPM-tmp Document 30-31 Filed 01/10/13 Page 2 of 2 PageID 251
`
`relating to the www.facebook.com website are stored in Facebooks' various data centers, which
`
`are accessible and ultimately managed from Menlo Park. The same is true for neady all of the
`
`information related to Facebooks' general operations, marketing, financials, and customer
`
`service.
`
`4.
`
`The vast majority of Facebook employees knowledgeable about the design,
`
`development, and operation of the www.facebook.com website are located at Facebook's Menlo
`
`Park headquarters.
`
`5. One Facebook employee resides .in Maryville, Tennessee, which is in the Eastern
`
`District of Tennessee. His title is Data Center Energy Managei;, and he is part of Facebook's
`
`Infrastructure Team. As indicated by his title, this employee manages the energy supply
`
`arrangements for Facebook's data centers, and his job responsibilities are unrelated to the display
`
`of advertising on any Faccbook website.
`
`6.
`
`Facebook has no offices, facilities, or employees working in the Western District of
`
`Tennessee. I am aware of no relevant documents located in the Western District of Tennessee.
`
`I declare under penalty of pe1jury under the laws of the United States that the foregoing is
`
`true and correct. Executed in Menlo Park) California on this 1 day of January, 2013.
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
