`
`Exhibit C
`
`
`
`Case 2:12-cv-02826-JPM-tmp Document 25-4 Filed 01/28/13 Page 2 of 4 PageID 145
`Case 2:12—cv—O2826—JPM—tmp Document 25-4 Filed 01/28/13 Page 2 of 4 Page|D 145
`
`UNITED STATES DISTRICT COURT
`
`WESTERN DISTRICT OF TENNESSEE
`
`WESTERN DIVISION
`
`
`B.E. Technology, L.L.C.,
`
`Plaintiff,
`
`V
`
`Civil Action No. 2:12-cv-02827—JPM—tmp
`
`Sony Mobile Communications (U.S.A.) Inc.,
`
`Defendant.
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`DECLERATION OF SUSANA CAPPER IN SUPPORT OF SONY MOBILE
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`COMMUNICATIONS (U.S.A) INC.’S MOTION TO TRANSFER VENUE PURSUANT
`TO 28 U.S.C. § l404(A) TO THE U.S. DISTRICT COURT FOR THE NORTHERN
`DISTRICT OF CALIFORNIA
`
`I, Susana Capper, 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 of Business Control and Planning at Sony Mobile
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`Communications (U.S.A.) Inc. (“SOMC”) in Atlanta, Georgia.
`
`I have been employed by SOMC
`
`since December 2009 (and before that by its foreign parent, Sony Ericsson Mobile
`
`Communications AB since October 2001).
`
`In this capacity, I have personal knowledge of the
`
`facts set forth.
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`2.
`
`3.
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`SOMC is a Delaware corporation.
`
`SoMC’s headquarters is located in Atlanta, Georgia. SoMC also has offices in
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`Redwood City, California. The Redwood City, California facility employs approximately 125
`
`persons and is the primary site for SoMC’s U.S.-based technology development efforts.
`
`
`
`Case 2:12-cv-02826-JPM-tmp Document 25-4 Filed 01/28/13 Page 3 of 4 PageID 146
`Case 2:12—cv—O2826—JPM—tmp Document 25-4 Filed 01/28/13 Page 3 of 4 Page|D 146
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`4.
`
`SoMC does not have any offices or other facilities within the Western District of
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`Tennessee.
`
`5.
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`I understand that Plaintiff B.E. Technology L.L.C. (“BET”) has filed a patent
`
`infringement lawsuit against SoMC and eighteen other defendants in the United States District
`
`Court for the Western District of Tennessee. BET has accused SoMC 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.
`
`6.
`
`Many potentially relevant documents and things related to the accused products in
`
`SoMC’s possession are likely located in its Redwood City, California offices, and most, if not
`
`all, relevant technical documents created by SoMC are created in its Redwood City, California
`
`offices.
`
`7.
`
`To the extent that SoMC is required to produce any witness in connection with
`
`this litigation, most SoMC technical witnesses will likely be located in Redwood City,
`
`California. In particular the following SoMC employees located in Redwood City, California
`
`may have relevant information: Kim Ahlstrom, Senior Manager, Research Labs Silicon Valley;
`
`Jorgen Birkler, Senior Manager; Martin Granstrorn, Senior Manager; Kuldeep Jain, Senior
`
`Systems Engineer, Software; Toshihiko Kii, Program Manager, Software; Wayne Moyung,
`
`Senior Verification Engineer, Software; and Minshik Roh, Director, Business & Partner
`
`Development. SoMC witnesses may also be located at the Atlanta facility. However, SoMC
`
`personnel regularly commute to the California office to meet and coordinate with personnel from
`
`
`
`Case 2:12-cv-02826-JPM-tmp Document 25-4 Filed 01/28/13 Page 4 of 4 PageID 147
`Case 2:12—cv—O2826—JPM—tmp Document 25-4 Filed 01/28/13 Page 4 of 4 Page|D 147
`
`other Sony companies. As a result, for SOMC employees, travel from Atlanta to Redwood City
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`is less burdensome than to most other US. locations.
`
`8.
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`I am unaware of any potential SoMC witnesses based in Tennessee.
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` Executed on January
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`2013.
`
`Susana Capper
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