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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
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`B.E. Technology, L.L.C.,
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`Civil Action No. 2:12-cv-02828-JPM-tmp
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`Plaintiff,
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`v.
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`Sony Electronics Inc.,
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`Defendant.
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`SONY ELECTRONICS INC.’S MOTION (WITH INCORPORATED MEMORANDUM)
`TO TRANSFER VENUE PURSUANT TO 28 U.S.C. § 1404(A) TO THE U.S. DISTRICT
`COURT FOR THE NORTHERN DISTRICT OF CALIFORNIA
`(WITH CERTIFICATE OF CONSULTATION)
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`Defendant Sony Electronics Inc. (“SEL”) respectfully moves this Court to transfer this
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`action to the United States District Court for the Northern District of California. The facts and
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`law supporting this relief are set forth in detail in the memorandum and exhibits supporting the
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`same motion filed in the related action against defendant’s affiliate, Sony Computer
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`Entertainment America LLC, Case No. 2:12-cv-02826-JPM-tmp, Doc. 25. SEL incorporates that
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`document in this motion by reference, to eliminate the necessity of the Court reviewing what
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`would be extensive duplicate information.
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`Case 2:12-cv-02828-JPM-tmp Document 24 Filed 01/28/13 Page 2 of 3 PageID 109
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`Respectfully submitted,
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`/s/ Glen G. Reid, Jr.___________________
`WYATT, TARRANT & COMBS, LLP
`1715 Aaron Brenner Drive, Suite 800
`Memphis, TN 38120-4367
`Phone: 901.537.1000
`Facsimile: 901.537.1010
`greid@wyattfirm.com
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`
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`/s/ Mark Vorder-Bruegge, Jr.___________
`Mark Vorder-Bruegge, Jr. (#06389)
`WYATT, TARRANT & COMBS, LLP
`1715 Aaron Brenner Drive, Suite 800
`Memphis, TN 38120-4367
`Phone: 901.537.1000
`Facsimile: 901.537.1010
`mvorder-bruegge@wyattfirm.com
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`OF COUNSEL
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`/s/ ___John Flock________
`John Flock (admission pending)
`jflock@kenyon.com
`Michael E. Sander (admission pending)
`msander@kenyon.com
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004-1007
`212.425.7200
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`Attorneys for Defendant Sony Electronics Inc.
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`CERTIFICATE OF CONSULTATION
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`I, Glen G. Reid, Jr., attorney for defendant, certify that I talked to Richard Carter on
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`December 7, 2012 regarding defendant’s intention to file the foregoing motion, and conferred
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`with him to determine whether the plaintiff would agree to the relief sought, such that the motion
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`could be presented as unopposed. The consultation was not successful and Mr. Carter advised
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`that the plaintiff opposes the motion.
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`s/Glen G. Reid, Jr.
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`-2-
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`Case 2:12-cv-02828-JPM-tmp Document 24 Filed 01/28/13 Page 3 of 3 PageID 110
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`CERTIFICATE OF SERVICE
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`The foregoing document was filed under the Court’s CM/ECF system, automatically
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`effecting service on counsel of record for all other parties who have appeared in this action on
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`the date of such service.
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`s/Glen G. Reid, Jr.
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`-3-
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