Case 2:17-cv-00513-JRG Document 36-6 Filed 11/14/17 Page 1 of 4 PageID #: 441
`
`Case 2:17-cv-00513-JRG Document 36-6 Filed 11/14/17 Page 1 of 4 PageID #: 441
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF TEXAS
`
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT, LLC
`
`Plamfi’
`
`V.
`
`CIVIL ACTION No. 2:17—cv—513-JRG
`
`HUAWEI DEVICE USA INC, HUAWEI
`DEVICE CO., LTD. AND HUAWEI DEVICE
`
`(DONGGUAN) CO., LTD.
`
`Defendants. r
`
`
`
`JURY TRIAL DEMANDED
`
`
`DECLARATION OF ABEER DUBEY REGARDING HUAWEI DEVICE USA INC.
`
`‘HUAWEI DEVICE CO., LTD. AND HUAWEI DEVICE [DONGGUAN] CO., LTD.’S
`MOTION TO TRANSFER VENUE TO THE NORTHERN DISTRICT OF CALIFORNIA
`
`I, Abeer Dubey, state and declare as follows:
`
`1.
`
`My title is Director, People Analytics. I work out of Google LLC’s (“Google”)
`
`Mountain View, California office.
`
`I submit this declaration based upon my knowledge of the
`
`corporate structure of Google, and my investigation of the location of witnesses and evidence
`
`related to certain Google products. If called as a witness, I could and would testify competently
`
`to the information contained herein.
`
`2.
`
`I understand that some of the applications that may be at issue in the
`
`above—captioned case are Google Hangouts, Google Plus, Android Messenger, and Google
`
`Messages.
`
`I am aware of no Google product named Android Messenger, but I am aware of a
`
`Google product named Android Messages. I am also aware of no Google product named Google
`
`Messages, but I am aware of a Google product named Messenger.
`
`I further understand that
`
`
`
`Case 2:17-cv-00513-JRG Document 36-6 Filed 11/14/17 Page 1 of 4 PageID #: 441
`
`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE EASTERN DISTRICT OF TEXAS
`
`MARSHALL DIVISION
`
`AGIS SOFTWARE DEVELOPMENT, LLC
`
`Plamfi’
`
`V.
`
`CIVIL ACTION No. 2:17—cv—513-JRG
`
`HUAWEI DEVICE USA INC, HUAWEI
`DEVICE CO., LTD. AND HUAWEI DEVICE
`
`(DONGGUAN) CO., LTD.
`
`Defendants. r
`
`
`
`JURY TRIAL DEMANDED
`
`
`DECLARATION OF ABEER DUBEY REGARDING HUAWEI DEVICE USA INC.
`
`‘HUAWEI DEVICE CO., LTD. AND HUAWEI DEVICE [DONGGUAN] CO., LTD.’S
`MOTION TO TRANSFER VENUE TO THE NORTHERN DISTRICT OF CALIFORNIA
`
`I, Abeer Dubey, state and declare as follows:
`
`1.
`
`My title is Director, People Analytics. I work out of Google LLC’s (“Google”)
`
`Mountain View, California office.
`
`I submit this declaration based upon my knowledge of the
`
`corporate structure of Google, and my investigation of the location of witnesses and evidence
`
`related to certain Google products. If called as a witness, I could and would testify competently
`
`to the information contained herein.
`
`2.
`
`I understand that some of the applications that may be at issue in the
`
`above—captioned case are Google Hangouts, Google Plus, Android Messenger, and Google
`
`Messages.
`
`I am aware of no Google product named Android Messenger, but I am aware of a
`
`Google product named Android Messages. I am also aware of no Google product named Google
`
`Messages, but I am aware of a Google product named Messenger.
`
`I further understand that
`
`
`
`Case 2:17-cv-00513-JRG Document 36-6 Filed 11/14/17 Page 2 of 4 PageID #: 442
`
`Case 2:17-cv-00513-JRG Document 36-6 Filed 11/14/17 Page 2 of 4 PageID #: 442
`
`Android Messages was formerly known as Messenger. For purposes of my investigation, I have
`
`investigated the location of witnesses and evidence related to Android Messages, Google
`
`Hangouts, and Google Plus.
`
`3.
`
`Google has been headquartered in Northern California since its founding in 1998.
`
`It has been headquartered in Mountain View, California since 2003. In 2007, Google opened its
`
`first office in San Francisco, California.
`
`4.
`
`Google’s Mountain View headquarters, which includes offices in neighboring
`
`Sunnyvale (collectively referred to as Mountain View herein), is the strategic center of Google’s-
`
`business. Google’s Mountain View headquarters houses thousands of employees making up
`
`approximately 35% of'Google’s total worldwide employees, including engineers, product
`
`managers, executives, and staff, particularly those performing work related to Android Messages,
`
`Google Hangouts and Google Plus. Google also employees several thousand employees in its
`
`San Francisco, California office.
`
`5.
`
`Many decisions related to Google’s overall business, including the most
`
`significant design and engineering decisions related to the Android Messages, Google Hangouts,
`
`Google Plus, involve managers and leads who work in Mountain View, California.
`
`6.
`
`According to Google’s investigation, most engineers and managers with relevant
`
`knowledge regarding the Android Messages application are based in or around Mountain View,
`
`California. In particular, I have been informed and understand that Drew Rowny, who is the
`
`Project Manager for Android Messages, is located in San Francisco, California, and several
`
`engineers responsible for various features related to Android Messages are located in Google’s
`
`Mountain View, California office.
`
`I have also been informed and understand that there are some
`
`
`
`Case 2:17-cv-00513-JRG Document 36-6 Filed 11/14/17 Page 3 of 4 PageID #: 443
`
`Case 2:17-cv-00513-JRG Document 36-6 Filed 11/14/17 Page 3 of 4 PageID #: 443
`
`engineers for Android Messages in Google’s Kirkland, Washington office, and that those
`
`engineers, along with Mr. Rowny and the engineers in Mountain View, California, work on
`
`various features of Android Messages.
`
`7.
`
`Additionally, according to Google’s investigation, engineers and managers with
`
`relevant knowledge regarding the Google Hangouts application are based in Mountain View,
`
`California. In particular, I have been informed and understand that Andrew Lee, who is the
`
`Technical Lead for Google Hangouts on Android, his direct reports, and the majority of the
`
`engineering team for Google Hangouts are all located in Google’s Sunnyvale, California office.
`
`8.
`
`Additionally, according to Google’s investigation, engineers and managers with
`
`relevant knowledge regarding the Google Plus application are based in Mountain View,
`
`California. In particular, I have been informed and understand that the team for Google Plus for
`
`Android, including Brian Johnson, who is the Technical Lead for that application,
`
`is located in
`
`Google’s Mountain View, California office.
`
`9.
`
`I am currently aware of no Google employees with relevant knowledge regarding
`
`the Android Messages, Google Hangouts, and Google Plus applications residing or working in
`
`the Eastern District of Texas. Moreover, Google has no offices or facilities within the Eastern
`
`District of Texas.
`
`10.
`
`Nearly all the documents relating to AndrOid Messages, Google Hangouts, and
`
`Google Plus, including highly proprietary information and source code, are either physically
`
`present in or electronically accessible from Mountain View, California, as that is where many of
`
`the personnel most qualified to identify and locate such documents reside.
`
`I am aware of no
`
`documents described in this paragraph being located in the Eastern District of Texas.
`
`
`
`Case 2:17-cv-00513-JRG Document 36-6 Filed 11/14/17 Page 4 of 4 PageID #: 444
`
`Case 2:17-cv-00513-JRG Document 36-6 Filed 11/14/17 Page 4 of 4 PageID #: 444
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed in
`
`Mountain View, California on November LL, 2017
`
`it} Q-L‘LLLZ a _
`
`Abeer Dubey
`
`C ‘
`
`
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