`Case 2:12—cv—O2830—JPM—tmp Document 22-2 Filed 12/18/12 Page 1 of 4 Page|D 128
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`EXHIBIT A
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`EXHIBIT A
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`
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`Case 2:12-cv-02830-JPM-tmp Document 22-2 Filed 12/18/12 Page 2 of 4 PageID 129
`Case 2:12—cv—O2830—JPM—tmp Document 22-2 Filed 12/18/12 Page 2 of 4 Page|D 129
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`UNITED STATES DISTRICT COURT
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`WESTERN DISTRICT OF TENNESSEE
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`WESTERN DIVISION
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`B.E. TECHNOLOGY, L.L.C.,
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`Plaintiff,
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`v.
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`GOOGLE INC.,
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`Defendant.
`
`
`Civil Action No. 12-cv-02830
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`Hon. John Phipps McCalla
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`DECLARATION OF ABEER DUBEY IN SUPPORT OF DEFENDANT’S MOTION
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`TO TRANSFER VENUE PURSUANT TO 28 U.S.C. § 140413]
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`I, Abeer Dubey, hereby declare:
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`1.
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`I am a People Analytics Manager at Defendant Google Inc. I submit this
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`declaration based upon my personal knowledge and corporate records maintained by Google in
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`the ordinary course of business. If called upon to testify, I could and would competently testify
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`thereto.
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`2.
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`Google has been headquartered in Northern California since its founding in 1998.
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`Google is presently headquartered in Mountain View, California.
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`3.
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`I understand that Plaintiff B.E. Technology, L.L.C. has identified the following as
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`accused products and services: “a method of providing demographically targeted advertising’?
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`- and “tablet computer products
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`[i]nclud[ing] Google Nexus products.”
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`4.
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`Based upon my understanding of what products a11d services have been accused
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`of infringement in this case, the individuals at Googie likely to have knowledge of the accused
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`products and services are all located in Northern California. To the extent any such individuals
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`may be located outside Mountain View, California, they would report to Google's headquarters
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`
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`Case 2:12-cv-02830-JPM-tmp Document 22-2 Filed 12/18/12 Page 3 of 4 PageID 130
`Case 2:12—cv—O2830—JPM—tmp Document 22-2 Filed 12/18/12 Page 3 of 4 Page|D 130
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`in Mountain View, California. Google employees most knowledgeable of the design,
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`development and operation of, and the financial information regarding these products and
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`services are located in Mountain View, California.
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`5.
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`Google‘s Mountain View, California location is the strategic center of Google's
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`business. Decisions related to Google‘s overall business are made in Mountain View, California,
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`including most significantly sales, marketing, and engineering decisions regarding Google's
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`products and services, and in particular‘, the accused products and services.
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`6.
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`Google does not have any offices or facilities in the Western District of
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`
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`Tennessee. I am not aware of the existence of any documents related to the accused products or
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`se1'vices that are located in the Western District of Tennessee. Specifically, I am not aware of any
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`Google employees working in the Western District of Tennessee with relevant knowledge
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`regarding the accused products or services or any other aspect of the subject matter of this
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`litigation.
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`7.
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`I am also not aware of any development or management of any of the accused
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`products or services occurring in the Western District of Tennessee. None of the employees
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`involved in product development or management of the accused products or services work in the
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`Western District of Tennessee.
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`8.
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`All, or nearly all, of the documents and highly proprietary information and source
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`code relating to the accused products and services are stored in Google's data centers that are
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`ultimately managed from Mountain View, California. The same is true for all or nearly all of the
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`information related to the general operations, marketing, financials, and customer service
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`information for Google.
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`
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`Case 2:12-cv-02830-JPM-tmp Document 22-2 Filed 12/18/12 Page 4 of 4 PageID 131
`Case 2:12—cv—O2830—JPM—tmp Document 22-2 Filed 12/18/12 Page 4 of 4 Page|D 131
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`I declare u11der penalty of perjury under the laws ofthe United States that the foregoing is
`true and correct. Executed in Mountain View, California on this 10th of December 2012.
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