`Case 2:12—cv—O2781—JPM—cgc Document 27-2 Filed 01/31/13 Page 1 of 1 Page|D 206
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`UNITED STATES DISTRICT COURT
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`WESTERN DISTRICT OF TENNESSEE
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`WESTERN DIVISION
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`Case No. 12-cv-02781-JPM cgc
`JURY DEMAND
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`5
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`5 )
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`B.E. TECHNOLOGY, L.L.C.,
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`Plaintiff/Counter-Defendant,
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`v.
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`GROUPON, INC.,
`Defendant/Counterclaimant.
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`DECLARATION OF JAMES LIN IN SUPPORT OF PLAINTIFF’S OPPOSITION T0
`DEFENDANT’S MOTION TO TRANSFER VENUE
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`PURSUANT TO 28 U.S.C. § 1404(a)
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`I, James Lin, declare as follows:
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`1.
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`I am an attorney with the law firm of Freitas Tseng & Kaufman LLP, counsel for
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`B.E. Technology, L.L.C.
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`I have personal knowledge of the facts stated in this Declaration and
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`could testify competently to them if asked to do so.
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`2.
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`Attached hereto as Exhibit A is a true and correct copy of excerpts of Groupon,
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`Inc.’s Form 10-Q for the quarterly period ended September 30, 2012.
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`3.
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`Attached hereto as Exhibit B is a true and correct copy of the 2011 Federal Court
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`Management Statistics for Northern District of California and the Western District of Tennessee.
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`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct.
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`Executed this 31st day of January, 2013, at Redwood S
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`California.
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`James Lg