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`Case 2:17-cv-00517—JRG Document 51-4 Filed 01/19/18 Page 1 of 2 PageID #: 627
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE EASTERN DISTRICT OF TEXAS
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`MARSHALL DIVISION
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`AGES SOFTWARE DEVELOPMENT, LLC
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`Plalntlffs
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`IL
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`CIVIL ACTION NO. 2:17—cv—513-JRG
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`HUAWEI DEVICE USA INC., HUAWEI
`DEVICE co, LTD. AND HUAWEI DEVICE
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`(DONGGUAN) co., LTD.
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`Defendants.
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`JURY TRIAL DEMANDED
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`DECLARATION OF ANDREW OPLINGER REGARDING DEFENDANTS’ MOTION
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`TO TRANSFER VENUE TO THE NORTHERN DISTRICT OF CALIFORNIA
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`1, Andrew Oplinger, state and declare as follows:
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`1.
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`Until December 2017, I was a Technical Lead Manager for Google Product
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`Infrastructure and work out of Google LLC’s (“Google”) Mountain View, California office.
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`I
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`submit this declaration based upon my personal knowledge, and, if calied as a witness, I could
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`and would testify competently to the information contained herein.
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`2.
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`I am aware that Google maintains relatively small offices in Austin, in the
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`Western District of Texas, and Dallas, in the Northern District of Texas. However, based on my
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`investigation, I am aware of no relevant witnesses in Google’s Austin office or Dallas office
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`related to the design, development, operation, or management of the Google Maps for Mobile
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`application (“GMM”) or Google’s Location Sharing functionality on GMM.
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`3.
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`Additionally, the source code used to compile the GMM application, including the
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`Location Sharing feature is not publicly available, is highly confidential, and maintained internaily
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`Case 2:17-cv-00517-JRG Document 51-4 Filed 01/19/18 Page 2 of 2 PageID #: 628
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`Case 2:17-cv-00517—JRG Document 51-4 Filed 01/19/18 Page 2 of 2 PageID #: 628
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`by the Google engineers responsible for GMM or Location Sharing, including the Google
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`personnel I previously identified in my first declaration.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed in
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`Mountain View, California on January 3, 2018
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