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`Exhibit A
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`
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`Case 2:12-cv-02826-JPM-tmp Document 25-2 Filed 01/28/13 Page 2 of 3 PageID 138
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
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`
`
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`B.E. Technology, L.L.C.,
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`
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`
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`Plaintiff,
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`
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`v.
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`Civil Action No. 2:12-cv-02826-JPM-tmp
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`
`
`
`
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`Sony Computer Entertainment America
`LLC,
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`
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`
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`Defendant.
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`DECLARATION OF JENNIFER Y. LIU IN SUPPORT OF SONY COMPUTER
`ENTERTAINMENT AMERICA LLC’S MOTION TO TRANSFER VENUE PURSUANT
`TO 28 U.S.C. § 1404(A) TO THE U.S. DISTRICT COURT FOR THE NORTHERN
`DISTRICT OF CALIFORNIA
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`
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`I, Jennifer Y. Liu, hereby declare under penalty of perjury that to the best of my
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`knowledge the following statements are true and correct:
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`1.
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`I am employed as Deputy General Counsel at Sony Computer Entertainment
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`America LLC (“SCEA”) in Foster City, California. I have been employed by SCEA since 2000.
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`In this capacity, I have personal knowledge of the facts set forth.
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`2.
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`3.
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`SCEA is a limited liability company.
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`SCEA’s headquarters is located at 919 East Hillsdale Boulevard, Foster City,
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`California 94404. SCEA also has two other offices within the Northern District of California,
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`located at 989 East Hillsdale Boulevard, Foster City, California 94404 and 950 Tower Lane,
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`
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`Case 2:12-cv-02826-JPM-tmp Document 25-2 Filed 01/28/13 Page 3 of 3 PageID 139
`Case 2:12—cv—O2826—JPM—tmp Document 25-2 Filed 01/28/13 Page 3 of 3 Page|D 139
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`Foster City, California 94404. SCEA has approximately 895 employees working in its Foster
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`City offices.
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`4.
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`SCEA does not have any offices or other facilities within the Western District of
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`Termessee.
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`5.
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`I understand that Plaintiff B.E. Technology L.L.C. has filed the above—captioned
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`patent infringement lawsuit against SCEA and eighteen other defendants in the United States
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`District Court for the Western District of Tennessee. SCEA’s accused products includethe
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`computer entertainment systems PlayStation 2 (“PS 2”), PlayStation 3 (“PS 3”), PlayStation
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`Portable (“PSP”) and PlayStation Vita (“PS Vita”).
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`6.
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`The potentially relevant U.S. documents and things related to the PS 2, PS 3, PSP,
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`and PS Vita in SCEA’s possession are located at its offices in Foster City, California.
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`7.
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`To the extent that SCEA is required to produce any witness in connection with
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`this litigation, all of SCEA’s known prospective witnesses are located at or near its offices in
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`Foster City, California, within the Northern District of California. In particular, SCEA’s
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`expected sales, finance, and marketing witnesses in connection with its accused products are
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`John Koller, Vice President, Product Marketing and Aaron Wong, Senior Lead Accountant, both
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`of whom work at SCEA’s Foster City offices and live within the Northern District of California.
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`8.
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`I am unaware of any potential SCEA witnesses who live in, work in or are
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`otherwise based in Tennessee.
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`Executed on Januaryzfi 2013.
`
`Jennifer Y. Liu
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