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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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`TWITTER, INC.,
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`Defendant.
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`Case No. 2:12-cv-02783-JPM
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`JURY DEMAND
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`DEFENDANT TWITTER, INC.’S MOTION TO TRANSFER VENUE
`PURSUANT TO 28 U.S.C. § 1404(a) AND FOR EXPEDITED CONSIDERATION
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`Defendant Twitter, Inc. (“Twitter”) respectfully moves this Court for an order
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`transferring this case to the U.S. District Court for the Northern District of California pursuant to
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`28 U.S.C. § 1404(a). This Motion is based on the accompanying Memorandum of Points
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`Authorities, the supporting declarations of Ed Axelsen and Clifford Webb, the pleadings and
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`records on file in the action, and upon such additional evidence and argument as may be
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`presented. Given that this Motion may result in transfer of this case out of the District and in
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`light of fast-approaching deadlines under this Court’s Patent Local Rules, Twitter respectfully
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`requests an expedited consideration of this Motion.
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`Case 2:12-cv-02783-JPM-cgc Document 30 Filed 01/28/13 Page 2 of 3 PageID 114
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`Respectfully submitted,
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`s/ Glen G. Reid, Jr.
`Glen G. Reid, Jr. (#8184)
`greid@wyattfirm.com
`Mark Vorder-Bruegge, Jr. (#06389)
`mvorder-bruegge@wyattfirm.com
`WYATT, TARRANT & COMBS, LLP
`The Renaissance Center
`1715 Aaron Brenner Dr., Suite 800
`Memphis, TN 38120-4367
`Ph: 901.537-1000; Fax: 901.537.1010
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`-and-
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`J. David Hadden
`Email: dhadden@fenwick.com
`Darren F. Donnelly
`Email: ddonnelly@fenwick.com
`Saina S. Shamilov
`Email: sshamilov@fenwick.com
`Ryan J. Marton
`Email: rmarton@fenwick.com
`Clifford Webb
`Email: cwebb@fenwick.com
`Justin G. Hulse
`Email: jhulse@fenwick.com
`FENWICK & WEST LLP
`801 California Street, 6th Floor
`Mountain View, CA 94041
`Ph: 650.988-8500; Fax: 650.938.5200
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`Attorneys for Defendant
`TWITTER, INC.
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`- 2 -
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`Case 2:12-cv-02783-JPM-cgc Document 30 Filed 01/28/13 Page 3 of 3 PageID 115
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`CERTIFICATE OF CONSULTATION
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`I, Glen Reid, attorney for defendant, certify that I talked to Richard Carter on December
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`7, 2012 regarding defendant’s intention to file the foregoing motion, and conferred with him to
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`determine whether plaintiff would agree to the relief sought, such that the motion could be
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`presented unopposed. The consultation was not successful and Mr. Carter advised that the
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`s/Glen G. Reid, Jr.
`Glen G. Reid, Jr.
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`plaintiff intends to oppose this motion.
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`CERTIFICATE OF SERVICE
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`The foregoing document was filed under the Court’s CM/ECF system, automatically
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`effecting service on counsel of record for all other parties who have appeared in this action on
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`the date of such service.
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` s/ Glen G. Reid, Jr.
`Glen G. Reid, Jr.
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