`Case 2:12—cv—O2830—JPM—tmp Document 37-1 Filed 01/29/13 Page 1 of 2 Page|D 298
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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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`Civil Action No. I2-cv-02830
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`‘
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`Hon. John Phipps McCalla
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`Defendant.
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`DECLARATION OF ABEER DUBEY IN SUPPORT OF DEFENDANT’S REPLY
`MEMORANDUM IN SUPPORT OF ITS 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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`I understand that Plaintiff B.E. Technology, L.L.C. has identified the following as
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`accused products and services in its infringement contentions: “Google Display Network
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`(including Adsense, Adwords), Google Offers, Google Offers Mobile Application, Google
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`Galaxy Nexus, Google Nexus 4, Google Nexus 7, Google Nexus 10, Google Nexus One, Google
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`Nexus S, Android Market, Google Play (including Play Store, Play Music, Play Books, Play
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`Magazines, and Play Movies & TV), and YouTube.”
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`3.
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`Based upon my understanding of what products and services have been accused
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`of infringement in this case, the majority of individuals at Google most knowledgeable of the
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`Case 2:12—cv—O2830—JPM—tmp Document 37-1 Filed 01/29/13 Page 2 of 2 Page|D 299
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`design, development and operation of the accused products and services are all located in the
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`Northern District of California, including at least Oren Zamir and Wei-Hsin Lee.
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`I declare under penalty of perjury under the laws of the United States that the foregoing is
`true and correct. Executed in Mountain View, California on this 28th of January 2013.
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`leawx