`Case 2:12—cv—O2825—JPM—tmp Document 31-13 Filed 01/22/13 Page 1 of 3 Page|D 227
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE WESTERN DISTRICT OF TENNESSEE
`
`WESTERN DIVISION
`
`B.E. TECHNOLOGY, L.L.C.,
`
`Plaintiff,
`
`V.
`
`CIVIL ACTION NO.
`
`2: 12—CV—02824-JPM-tmp
`
`JURY TRIAL DEMANDED
`
`SAMSUNG TELECOMMUNICATIONS
`
`AMERICA LLC,
`
`Defendants.
`
`DECLARATION OF JUSTIN DENISON IN SUPPORT OF SAMSUNG’S MOTION TO
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`TRANSFER VENUE TO THE DISTRICT OF NEW JERSEY
`
`1, Justin Denison, hereby declare and state as follows:
`
`1.
`
`1 am the Chief Strategy Officer at Samsung Telecommunications America, LLC
`
`(“STA”).
`
`I have held this position for approximately 10 months and have been employed by
`
`STA in various positions since May of 2008.
`
`I submit this declaration in support of Samsung’s
`
`Motion To Transfer Venue To The District of New Jersey. The statements in this declaration are
`
`based upon my personal knowledge or corporate records maintained by STA in the ordinary
`
`course of business.
`
`2.
`
`STA, a Delaware limited liability company,
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`is a wholly owned subsidiary of
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`Samsung Electronics America, Inc. (“SEA”). STA’s corporate headquarters are located at 1301
`
`East Lookout Dr., Richardson, Texas 75082, which is where I work.
`
`I reside in Allen, Texas.
`
`3.
`
`STA develops and commercializes a variety of wireless communication devices
`
`across the United States, including smartphones, cellular-equipped tablets, and Galaxy cameras.
`
`4.
`
`I have been advised that B.E. Technology, L.L.C. (“B.E. Technology”) has filed
`
`NY 242$/3?2?3v3
`
`
`
`Case 2:12-cv-02825-JPM-tmp Document 31-13 Filed 01/22/13 Page 2 of 3 PageID 228
`Case 2:12—cv—O2825—JPM—tmp Document 31-13 Filed 01/22/13 Page 2 of 3 Page|D 228
`
`patent infringement lawsuits against STA and SEA (collectively, “Defendants” or ‘‘Samsung’‘).
`
`I
`
`understand that B.E. Technology has accused several Samsung products of infringing its patent,
`
`including certain smartphones, tablets, Blu«ray Disc players, Smart TVs, cameras, media players,
`
`home theater systems, and personal computers through the inclusion and use of certain software
`
`and services developed by Samsung, Google, Microsoft, Amazon, Netflix, Hulu, Barnes &
`
`Noble, and Kno Inc.
`
`5.
`
`In my position as Chief Strategy Officer, I lead the corporate planning process for
`
`STA. My team conducts market analysis on behalf of the organization, helps facilitate some of
`
`the strategic decision making inside the company and has corporate development responsibilities
`
`for new growth opportunities for STA.
`
`I have knowledge of sales and marketing involving all of
`
`STA's products.
`
`6.
`
`The majority of potentially relevant documents and things
`
`related to the
`
`marketing, sale, and distribution of the accused smartphones, cellular-equipped tablets, and
`
`Galaxy cameras sold by STA (the “Accused STA Products”) are physically located at STA’s
`
`offices in Richardson, Texas.
`
`7.
`
`I am informed and believe that potentially relevant financial information related
`
`to the Accused STA Products is stored on servers in New Jersey.
`
`8.
`
`The majority of potential witnesses from STA with relevant knowledge
`
`concerning the accused products, including me, work at STA’s offices in Richardson, Texas, and
`
`reside nearby.
`
`9.
`
`STA has a facility in Bridgewater, New Jersey.
`
`STA personnel at
`
`the
`
`Bridgewater, New Jersey facility perform some research and development
`
`related to
`
`smartphones.
`
`NY 242737273V3
`
`
`
`Case 2:12-cv-02825-JPM-tmp Document 31-13 Filed 01/22/13 Page 3 of 3 PageID 229
`Case 2:12—cv—O2825—JPM—tmp Document 31-13 Filed 01/22/13 Page 3 of 3 Page|D 229
`
`10.
`
`STA has no facilities in Tennessee.
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`11.
`
`I am informed and believe that STA also conducts certain operations out of
`
`facilities in San Jose, California.
`
`12.
`
`I am informed and believe that other STA employees with potentially relevant
`
`knowledge concerning the development, commercialization, design, and manufacture of the
`
`Accused STA Products also travel
`
`to Samsung’s facilities in Ridgefield, New Jersey in
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`connection with their employment at STA.
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`13.
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`None of the Accused STA Products are manufactured in or purchased from
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`entities located in the Western District of Tennessee.
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`***
`
`I declare under the penalty of perjury under the laws of the United States that the
`
`foregoing is true and correct.
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`Executed January _, 2013, in Richardson, Texas.
`
`tin Denison
`
`N Y 24273 72 73 V3
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