`Case 2:12—cv—O2825—JPM—tmp Document 42 Filed 02/21/13 Page 1 of 2 Page|D 417
`
`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.
`
`
`B.E. TECHNOLOGY, L.L.C.,
`
`Plaintiff,
`
`V.
`
`CIVIL ACTION NO.
`
`2:12—CV-02825-JPM—trnp
`
`JURY TRIAL DEMANDED
`
`SAMSUNG ELECTRONICS AMERICA,
`INC.,
`
`
`
`Defendants.
`
`DECLARATION OF JUSTIN A. MACLEAN IN SUPPORT OF SAMSUNG’S REPLY
`
`MEMORANDUM SUPPORTING ITS MOTION TO TRANSFER VENUE
`
`1, Justin A. MacLean, hereby declare and state as follows:
`
`1.
`
`I am an associate in the New York office of Greenberg Traurig, LLP (“GT”),
`
`located at 200 Park Avenue, New York, NY 10166.
`
`I submit this declaration in support of
`
`Defendants Samsung Telecommunications America LLC (“STA”) and Samsung Electronics
`
`America, Inc.’s (“SEA”) (collectively, “Samsung”) Motion to Transfer Venue to the District of
`
`New Jersey (“Motion”).
`
`This declaration is based upon facts of which I have personal
`
`knowledge.
`
`
`
`Case 2:12-cv-02825-JPM-tmp Document 42 Filed 02/21/13 Page 2 of 2 PageID 418
`Case 2:12—cv—O2825—JPM—tmp Document 42 Filed 02/21/13 Page 2 of 2 Page|D 418
`
`2.
`
`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
`
`State, dated September 6, 2012.
`
`3.
`
`Attached hereto as Exhibit 2 is a true and correct copy of B.E.’s 2013 Annual
`
`Statement
`
`filed with the Michigan Secretary of State and retrieved from the Michigan
`
`Department of Licensing and Regulatory Affairs website.
`
`4.
`
`Attached hereto as Exhibit 3 is a true and correct copy of excerpts from the file
`
`history for U.S. Patent Publication No. 2012-0158512.
`
`5.
`
`On January 7, 2013, counsel for B.E. Technology, LLC (“B.E.”) produced
`
`documents pursuant to Local Patent Rule 3.2(b) along with its initial infringement contentions.
`
`That production was comprised of 222 documents. Attached hereto as Exhibit 4 is a true and
`
`correct copy of the cover letter to that production sent by B.E.’s counsel in the Northern District
`
`of California.
`
`6.
`
`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
`
`Local Patent Rule 3.1(c). The complete Appendix A totaled 10,363 pages.
`
`I declare under the penalty of perjury under the laws of the United States that the
`
`foregoing is true and correct.
`
`Executed in New York, New York on February 21, 2013.
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