`
`Exhibit B
`
`
`
`Case 2:12-cv-02826-JPM-tmp Document 25-3 Filed 01/28/13 Page 2 of 4 PageID 141
`
`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`
`
`
`
`
`
`
`B.E. Technology, L.L.C.,
`
`
`Sony Electronics Inc.,
`
`
`
`
`
`Defendant.
`
`
`
`
`
`
`
`DECLARATION OF MATTHEW SEYMOUR IN SUPPORT OF SONY ELECTRONICS
`INC.’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
`
`
`
`I, Matthew Seymour, declare under penalty of perjury that to the best of my knowledge
`
`the following statements are true and correct:
`
`1.
`
`I am employed as Director, Product Marketing, Home Division at Sony
`
`Electronics Inc. (“SEL”) in San Diego, California. I have been employed by SEL since 1995. In
`
`this capacity, I have personal knowledge of the facts set forth.
`
`2.
`
`3.
`
`SEL is a Delaware corporation.
`
`SEL’s headquarters is located at 16530 Via Esprillo, San Diego, California 92127.
`
`There are approximately 1,244 SEL employees in San Diego. SEL’s San Diego campus employs
`
`software engineers, service engineers, and quality assurance support engineers that test products
`
`for use in the field and test software for compliance with U.S. market requirements.
`
`
`
`
`
`Plaintiff,
`
`
`
`v.
`
`Civil Action No. 2:12-cv-02828-JPM-tmp
`
`
`
`
`
`
`
`Case 2:12-cv-02826-JPM-tmp Document 25-3 Filed 01/28/13 Page 3 of 4 PageID 142
`
`
`4.
`
`SEL’s San Diego campus also houses the company’s corporate financial, sales
`
`and marketing documentation. Employees at the San Diego office manage the company’s sales,
`
`distribution, and customer service departments, and are responsible for its U.S. marketing
`
`strategies, platform development, market research, and tradeshow exhibits.
`
`5.
`
`SEL also has a facility located at 1730 North First Street, San Jose, California
`
`95112. Approximately 245 employees work at the San Jose facility including members of the
`
`Digital Reader Business (“DRBD”) who primarily handle software and quality assurance
`
`engineering, as well as some marketing, testing associated with content-supporting applications,
`
`and other various support roles.
`
`6.
`
`SEL does not have any offices or other facilities within the Western District of
`
`Tennessee.
`
`7.
`
`I understand that Plaintiff B.E. Technology L.L.C. (“BET”) has filed a patent
`
`infringement lawsuit against SEL and eighteen other defendants in the United States District
`
`Court for the Western District of Tennessee. BET has accused SEL of patent infringement by
`
`making, selling, or offering the following categories of products and/or services: app stores, Blu-
`
`ray players, desktop computers, e-readers, gaming consoles, gaming websites, home-theater
`
`systems, internet video websites, laptop computers, mobile phones, music players, online video
`
`services, streaming players, tablets, and televisions.
`
`8.
`
`SEL products are generally designed in Japan and quality assurance engineering
`
`takes place in California. As a result, nearly all of the potentially relevant U.S. documents and
`
`things related to the accused products in SEL’s possession are located in its California offices.
`
`-2-
`
`
`
`Case 2:12-cv-02826-JPM-tmp Document 25-3 Filed 01/28/13 Page 4 of 4 PageID 143
`Case 2:12—cv—O2826—JPM—tmp Document 25-3 Filed 01/28/13 Page 4 of 4 Page|D 143
`
`9.
`
`To the extent that SEL is required to produce any witness in connection with this
`
`litigation, nearly all known SEL U.S.-based witnesses are located in California. In particular,
`
`SEL employees listed in the table below may have relevant information:
`
`Name
`
`Title
`
`Kevin Brinkman
`
`Yang Cheng
`Chris Goodman
`
`Sr. Mgr., TV Product
`Marketing
`Sr. M r., Product Stratey
`Vice Pres., Finance
`
`Product
`
`Televisions
`
`San Diego, CA
`
`
`
`Streamin Media Player
`Televisions, Blu-ray/DVDs,
`Tablets, Readers, Streaming
`Media Pla ers
`
`San Diego, CA
`San Diego, CA
`
`Natascha Helbig Dir., Product Marketing,
`Reader Store
`
`i Klaus Hofrichter Vice Pres., UXSC Home
`
`Hiraku Inoue
`
`Vice Pres., Software En.
`
`Tiger Izaki
`
`Lordita Canlas
`
`Jamie Marsh
`Ken Orii
`Julie Reynosa
`Mark Schmidt
`Oscar Vega
`Lisa Wayne
`
`Director, Product Planning
`& Strategy
`Sr. Marketing Mgr., Core
`Video/HMD
`
`Sr. Product Marketing Mgr.
`Vice Pres., Marketing
`Director, Business Planning
`Dir., QA En ineerin
`Vice Pres., UX Engineering
`Dir., Business Operations
`
`Readers
`
`Televisions
`
`Readers
`
`Televisions
`
`San Jose, CA
`
`San Diego, CA
`
`San Jose, CA
`
`San Diego, CA
`
`Blu-ray/DVDs
`
`San Diego, CA
`
`Tablets
`Readers
`Televisions, Blu-ray/DVDs
`Televisions
`Televisions
`Tablets
`
`San Diego, CA
`San Die 0, CA
`San Die 0, CA
`San Diego, CA
`— San Die 0, CA
`San Die 0, CA
`
`—
`
`10.
`
`I am unaware of any potential SEL witnesses based in Tennessee.
`
`Executed on January 18, 2013.
`
`Matthew Seymour
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
