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Case 2:12-cv-02825-JPM-tmp Document 31 Filed 01/22/13 Page 1 of 3 PageID 106
`
`
`
`
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`
`B.E. TECHNOLOGY, L.L.C.,
`
`
`
`Plaintiff,
`
`
`
`
`
`
`
`v.
`
`Civil Action No. 12-cv-02824-JPM-cgc
`
`JURY TRIAL DEMANDED
`
`SAMSUNG TELECOMMUNICATIONS
`AMERICA, LLC,
`
`
`
`Defendant.
`
`
`
`B.E. TECHNOLOGY, L.L.C.,
`
`
`
`Plaintiff,
`
`
`
`
`
`
`
`v.
`
`SAMSUNG ELECTRONICS AMERICA
`INC.,
`
`Civil Action No. 12-cv-02825-JPM-tmp
`
`JURY TRIAL DEMANDED
`
`
`
`Defendant.
`
`
`DEFENDANTS SAMSUNG TELECOMMUNICATIONS AMERICA, LLC AND
`SAMSUNG ELECTRONICS AMERICA INC.’S MOTION TO TRANSFER VENUE
`PURSUANT TO 28 U.S.C. § 1404(a)
`
`
`
`
`
`Defendants
`
`Samsung Electronics America,
`
`Inc.
`
`(“SEA”)
`
`and
`
`Samsung
`
`Telecommunications America, LLC (“STA”) respectfully move this Court to transfer the above-
`
`styled cases to the United States District Court for the District of New Jersey, pursuant to 28
`
`U.S.C. § 1404(a). In support of their Motion, SEA and STA rely on the Memorandum in
`
`Support of Their Motion to Transfer and the Declarations and Exhibits attached thereto, filed
`
`contemporaneously herewith.
`
`Respectfully submitted,
`
`/s/ Jonathan E. Nelson
`Shepherd D. Tate (TN BPR #05638)
`
`
`
`
`
`
`
`-1-
`
`

`
`Case 2:12-cv-02825-JPM-tmp Document 31 Filed 01/22/13 Page 2 of 3 PageID 107
`
`
`
`
`
`
`
`
`
`Jonathan E. Nelson (TN BPR #028029)
`BASS, BERRY & SIMS, PLC
`100 Peabody Place, Suite 900
`Memphis, Tennessee 38103
`Telephone: (901) 543-5900
`Facsimile:
`(901) 543-5999
`Email:
`state@bassberry.com
`
`jenelson@bassberry.com
`
`Richard C. Pettus (admitted pro hac vice)
`Justin Raskin (admitted pro hac vice)
`Justin A. MacLean (admitted pro hac vice)
`GREENBERG TRAURIG, LLP
`200 Park Avenue
`New York, NY 10166
`Telephone:
`(212) 801-9200
`Facsimile:
`(212) 801-6400
`Email:
`pettusr@gtlaw.com
`
`
`raskinj@gtlaw.com
`
`
`macleanj@gtlaw.com
`
`Attorneys for Defendants, Samsung Electronics
`America, Inc. and Samsung Telecommunications
`America, LLC
`
`-2-
`
`

`
`Case 2:12-cv-02825-JPM-tmp Document 31 Filed 01/22/13 Page 3 of 3 PageID 108
`
`
`
`
`
`CERTIFICATE OF CONSULTATION
`
`
`I, Jonathan Nelson, attorney for Defendants Samsung Electronics America, Inc. and
`
`Samsung Telecommunications America, LLC, certify that I spoke with Richard Carter on
`
`January 22, 2013 regarding Defendants’ intention to file the foregoing Motion, and conferred
`
`with him to determine whether the Plaintiff would agree to the relief sought, such that the
`
`Motion could be presented as unopposed. The consultation was not successful and Mr. Carter
`
`advised that the Plaintiff opposes the Motion.
`
` /s/ Jonathan Nelson
`Jonathan Nelson
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`
`
`The foregoing document was filed under the Court’s CM/ECF system, automatically
`
`effecting service on counsel of record for all other parties who have appeared in this action on
`
`the date of such service.
`
`
`
` /s/ Jonathan Nelson
`
`
`
`11536150.1
`
`
`
`-3-

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