`Case 2:12—cv—O2824—JPM—tmp Document 38 Filed 02/21/13 Page 1 of 2 Page|D 413
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE WESTERN DISTRICT OF TENNESSEE
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`WESTERN DIVISION
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`B.E. TECHNOLOGY, L.L.C.,
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`Plaintiff,
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`V.
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`CIVIL ACTION NO.
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`2: 12-CV-02824-JPM-tmp
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`JURY TRIAL DEMANDED
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`SAMSUNG TELECOMMUNICATIONS
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`AMERICA LLC.,
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`Defendants.
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`B.E. TECHNOLOGY, L.L.C.,
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`Plaintiff,
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`V.
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`CIVIL ACTION NO.
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`2:12—CV-02825-JPM—trnp
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`JURY TRIAL DEMANDED
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`SAMSUNG ELECTRONICS AMERICA,
`INC.,
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`Defendants.
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`DECLARATION OF JUSTIN A. MACLEAN IN SUPPORT OF SAMSUNG’S REPLY
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`MEMORANDUM SUPPORTING ITS MOTION TO TRANSFER VENUE
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`1, Justin A. MacLean, hereby declare and state as follows:
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`1.
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`I am an associate in the New York office of Greenberg Traurig, LLP (“GT”),
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`located at 200 Park Avenue, New York, NY 10166.
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`I submit this declaration in support of
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`Defendants Samsung Telecommunications America LLC (“STA”) and Samsung Electronics
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`America, Inc.’s (“SEA”) (collectively, “Samsung”) Motion to Transfer Venue to the District of
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`New Jersey (“Motion”).
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`This declaration is based upon facts of which I have personal
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`knowledge.
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`Case 2:12-cv-02824-JPM-tmp Document 38 Filed 02/21/13 Page 2 of 2 PageID 414
`Case 2:12—cv—O2824—JPM—tmp Document 38 Filed 02/21/13 Page 2 of 2 Page|D 414
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`2.
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`Attached hereto as Exhibit 1 is a true and correct copy of B.E. Technology,
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`L.L.C.’s (“B.E.”) Application for Certificate of Authority received by the Tennessee Secretary of
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`State, dated September 6, 2012.
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`3.
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`Attached hereto as Exhibit 2 is a true and correct copy of B.E.’s 2013 Annual
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`Statement
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`filed with the Michigan Secretary of State and retrieved from the Michigan
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`Department of Licensing and Regulatory Affairs website.
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`4.
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`Attached hereto as Exhibit 3 is a true and correct copy of excerpts from the file
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`history for U.S. Patent Publication No. 2012-0158512.
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`5.
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`On January 7, 2013, counsel for B.E. Technology, LLC (“B.E.”) produced
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`documents pursuant to Local Patent Rule 3.2(b) along with its initial infringement contentions.
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`That production was comprised of 222 documents. Attached hereto as Exhibit 4 is a true and
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`correct copy of the cover letter to that production sent by B.E.’s counsel in the Northern District
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`of California.
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`6.
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`Attached hereto as Exhibit 5 is a true and correct copy of an excerpt from Exhibit
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`A to Plaintiffs Infringement Contentions, served on Samsung on January 7, 2013, which is an
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`exemplar chart of one of the 177 Samsung products accused of infringement purportedly under
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`Local Patent Rule 3.1(c). The complete Appendix A totaled 10,363 pages.
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`I declare under the penalty of perjury under the laws of the United States that the
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`foregoing is true and correct.
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`Executed in New York, New York on February 21, 2013.