`
`IN THE UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`
`Civil Action No. 2:12-cv-2829 JPM tmp
`
`))))))))))
`
`B.E. TECHNOLOGY, L.L.C.,
`
`Plaintiff,
`
`V.
`
`MICROSOFT CORPORATION,
`
`Defendant.
`
`DECLARATION OF LEERON G. KALAY IN SUPPORT OF MICROSOFT
`CORPORATION'S MOTION TO TRANSFER VENUE
`
`I, Leeron G. Kalay, declare:
`
`1. I am an attorney with Fish & Richardson P.C., counsel of record in this action for
`
`Defendant, Microsoft Corporation. ("Microsoft"). I am a member of the Bar of the State of
`
`California. I have personal knowledge of the matters stated in this declaration and would testify
`
`truthfully to them if called upon to do so.
`
`2. Attached as Exhibit A is a true and correct copy of the Delaware Secretary of
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`State Entity Details for B.E. Technology, L.L.C.
`
`3. Attached as Exhibit B is a true and correct copy of the Michigan Corporate
`
`Records and Business Registrations for B.E. Technology, L.L.C.
`
`4. Attached as Exhibit C is a true and correct copy of excerpts of a document titled
`
`"Big Easy Technologies, L.L.C., Business Plan," dated May 8, 2000.
`
`
`
`Case 2:12-cv-02829-JPM-tmp Document 32 Filed 01/18/13 Page 2 of 3 PageID 158
`
`5. Attached as Exhibit D is a true and correct copy of an archived web page for
`
`www.betechnology.com/company/index.htm, dated January 4, 2001, obtained from the Internet
`
`Archive (http://web.archive.org).
`
`6. Attached as Exhibit E is a true and correct copy of a redacted LexisNexis public
`
`records report for Mark McKinley.
`
`7. Attached as Exhibit F is a true and correct copy of a redacted LexisNexis public
`
`records report for David Stavenger.
`
`8. Attached as Exhibit G is a true and correct copy of United States Patent
`
`Publication No. 2012/0158512.
`
`9. Attached as Exhibit H is a true and correct copy of the United States Patent and
`
`Trademark Assignment data for U.S. Patent No. 6,628,314, from the USPTO Assignments on the
`
`Web.
`
`10. Attached as Exhibit I is a true and correct copy of the United States Patent and
`
`Trademark Assignment data for U.S. Patent No. 6,771,290, from the USPTO Assignments on the
`
`Web.
`
`11. Attached as Exhibit J is a true and correct copy of B.E. Technology, L.L.C.'s
`
`Application for Certificate of Authority received by Tennessee Secretary of State, dated
`
`September 6, 2012.
`
`12. Attached as Exhibit K is a true and correct copy of redacted Property Record for
`
`116 W. Viking Dr., Cordova, TN 38018-7261, from the Office of the Shelby County, TN
`
`Register.
`
`13. Attached as Exhibit L is a true and correct copy of excerpts from the file history
`
`for U.S. Patent Publication No. 2012-0158512.
`
`2
`
`
`
`Case 2:12-cv-02829-JPM-tmp Document 32 Filed 01/18/13 Page 3 of 3 PageID 159
`
`14. Attached as Exhibit M is a true and correct copy of U.S. Patent Publication No.
`
`2008-0288874.
`
`15. Attached as Exhibit N is a true and correct copy of B.E. Technology's Initial
`
`Infringement Contentions (without appendices).
`
`16. Attached as Exhibit O is a true and correct copy of U.S. Patent No. 5,724,521.
`
`17. Attached as Exhibit P is a true and correct copy of U.S. Patent No. 5,710,884.
`
`18. Attached as exhibit Q is a true and correct copy ofNetGravity AdServer
`
`AdMaster's Guide.
`
`19. Attached as Exhibit R is a true and correct copy of U.S. Patent No. 5,740,549.
`
`20. Attached as Exhibit S is a true and correct copy of the March 2012 Federal Court
`
`Management Statistics for the Western District of Washington.
`
`21. Attached as Exhibit T is a true and correct copy of the March 2012 Federal Court
`
`Management Statistics for the Western District of Tennessee.
`
`22. Attached as Exhibit U is a true and correct copy of the March 2012 Federal Court
`
`Management Statistics for the Northern District of California.
`
`I declare under penalty of perjury under the laws of the United States that the foregoing is
`
`true and correct.
`
`Executed this 18th day of January, 2013 at Redwood City, California.
`
`Leeron G. Kalay
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