`Case 2:12—cv—O2866—JPM—tmp Document 18-2 Filed 12/19/12 Page 1 of 3 Page|D 94
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`EXHIBIT A
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`EXHIBIT A
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`
`
`
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`Case 2:12-cv-02866-JPM-tmp Document 18-2 Filed 12/19/12 Page 2 of 3 PageID 95
`Case 2:12—cv—O2866—JPM—tmp Document 18-2 Filed 12/19/12 Page 2 of 3 Page|D 95
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`UNITED STATES DISTRICT COURT
`WESTERN DISTRICT OF TENNESSEE
`WESTERN DIVISION
`
`B.E. TECHNOLOGY, L.L.C.,
`
`Plaintiff,
`
`v.
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`Civil Action N0. 12-cv-02866
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`MOTOROLA MOBILITY HOLDINGS LLC.,
`
`Hon. John Phipps McCalla
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`Defend ant.
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`
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`DECLARATION OF THOMAS V. MILLER IN SUPPORT OF
`DEFENDANT’S MOTION TO TRANSFER VENUE PURSUANT TO 28 U.S.C.
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`I, Thomas V. Miller, hereby declare:
`
`1.
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`I am Vice President, Intellectual Property at Motorola Mobility LLC
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`(“Motorola”).
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`I submit this declaration based upon my personal knowledge and coiporate
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`records maintained by Motorola in the ordinary course of business. If called upon to testify, I
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`could and would competently testify thereto.
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`2.
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`Motorola is a Delaware corporation presently l1e'adquarte1'ed in Libertyville,
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`Illinois, with its principle place of business at 600 N. U.S. Highway 45, Libertyville, Illinois
`60048. Motorola has offices in Sunnyvale and San Diego, California.
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`3.
`
`4.
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`Motorola is a wholly—owned subsidiary of Google Inc.
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`I understand that Plaintiff B.E. Technology, L.L.C. has identified the following as
`
`accused products: “Motorola tablets: Xyboard and Xoom tablets; Motorola smaitphones: Atrix,
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`Electrify 2, Defy XT, Photon Q 4G LTE.” All of these products include the Google Android
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`operating system. Further, I understand that B.E. Technology, L.L.C. has also identified Google
`I
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`Play, a Google product.
`
`
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`Case 2:12-cv-02866-JPM-tmp Document 18-2 Filed 12/19/12 Page 3 of 3 PageID 96
`Case 2:12—cv—O2866—JPM—tmp Document 18-2 Filed 12/19/12 Page 3 of 3, Page|D 96
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`5.
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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, a number of the individuals likely to have knowledge of the accused
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`products and services are located in Northern California. The Google employees most
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`knowledgeable of the design, development and operation of Google’s Android operating system
`
`and Google play are located at Google in Mountain View, California. In addition, some
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`Motorola employees with knowledge of the accused products are located in California, including
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`Sunnyvale and San Diego, California.
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`6.
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`Motorola does not have any offices, facilities, or employees working in
`
`Tennessee. I am not aware of the existence of any documents related to the accused products or
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`services that are located in Tennessee. Specifically, I am not aware of any Motorola employees
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`working in Tennessee with relevant knowledge regarding the accused products or services or any
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`other aspect of the subject matter of this litigation.
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`7.
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`I am not aware of any development or management of any of the accused
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`products or services occurring in Tennessee. None of the employees involved in product
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`development or management of the accused products or services work in Tennessee.
`
`I declare under penalty ofperjury under the lawspf the United States that the foregoing is
`true and correct. Executed in érfitfirrckigf R on this
`of December 2012.
`
`. =
`....._.,
`,
`/.»
`ii .//X
`
`J
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