Case 4:23-cv-01147-ALM Document 22-2 Filed 05/23/24 Page 1 of 5 PageID #: 425
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
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`R2 SOLUTIONS LLC,
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`Plaintiff,
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`v.
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`DATABRICKS, INC.,
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`Civil Action No. 4:23-cv-01147-ALM
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`JURY TRIAL DEMANDED
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`Defendant.
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`DECLARATION OF ABHINAV TANEJA IN SUPPORT OF DEFENDANT’S
`MOTION TO TRANSFER VENUE TO THE NORTHERN DISTRICT OF CALIFORNIA
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`Case 4:23-cv-01147-ALM Document 22-2 Filed 05/23/24 Page 2 of 5 PageID #: 426
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`I, Abhinav Taneja, declares as follows:
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`1.
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`My name is Abhinav Taneja. I am a citizen of the United States and am at least
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`eighteen years of age. I have personal knowledge of and am competent to testify as to the facts
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`herein.
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`2.
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`I have been an employee at Databricks, Inc. (“Databricks”) since 2021. I am
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`currently Vice President of Research & Development Operations (“R&D Operations”) of
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`Databricks.
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`3.
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`In my role as Databricks’ Vice President of R&D Operations, I am familiar with
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`Databricks’ research, development, design, marketing, distribution, and sales of its products and
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`services. I am based in the San Francisco Bay Area, California.
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`4.
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`Databricks is a Delaware corporation, and is and has always been headquartered in
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`the San Francisco Bay Area, California. Databricks maintains three offices in Northern California,
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`including in San Francisco, Mountain View, and Berkeley.
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`5.
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`I understand that the Plaintiff in this case, R2 Solutions LLC, filed a complaint that
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`identifies the “Databricks Data Intelligence Platform/Databricks Lakehouse Platform, and any
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`other platform(s) offered or provided by Databricks that utilize Apache Spark or any other similar
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`functionality” as the “Accused Instrumentalities.”
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`6.
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`Apache Spark started as a research project at the University of California Berkeley
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`(“UC Berkeley”) in 2009. UC Berkeley is located in the San Francisco Bay Area, California.
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`Case 4:23-cv-01147-ALM Document 22-2 Filed 05/23/24 Page 3 of 5 PageID #: 427
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`Apache Spark is an open-source analytics engine used for big data workloads and machine
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`learning. The Apache Spark project was made available as open-source software in 2010 and
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`donated to The Apache Software Foundation in 2013.
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`Databricks was founded in 2013 in the San Francisco Bay Area, California.
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`8.
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` The Databricks Platform was designed and developed to implement
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`Apache Spark, and such design and development was done primarily by Databricks engineers
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`based in Northern California.
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`9.
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`The Databricks Platform was designed and developed to utilize Apache Spark, and
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`such design and development occurred primarily in Northern California.
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`Case 4:23-cv-01147-ALM Document 22-2 Filed 05/23/24 Page 4 of 5 PageID #: 428
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`11.
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`Documents concerning the design, development, and operation of the Databricks
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`Platform (including source code), as well as any financial documentation, are primarily generated
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`in the San Francisco Bay Area, California.
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`12.
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`Databricks has a small WeWork location in Plano, Texas.
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` I
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` declare under penalty of perjury that the foregoing is true and correct.
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`Executed in _______________________, California, on May 21, 2024.
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`Abhinav Taneja
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`3
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`Mountain View
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`Case 4:23-cv-01147-ALM Document 22-2 Filed 05/23/24 Page 5 of 5 PageID #: 429
`Case 4:23-cv-01147-ALM Document 22-2 Filed 05/23/24 Page 5 of 5 PagelD #: 429
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`CERTIFICATE OF SERVICE
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`I herebycertify that all counsel of record who are deemed to have consented to electronic
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`service are being served with a copy of this document via the Court’s CM/ECFsystem per Local
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`Rule CV-5(a)(3) on May 21, 2024. Additionally, I hereby certify that all counsel of record who
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`consented to electronic service are being served with a copy of this documentvia electronic mail
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`per Local Rule CV-S.
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`/s/ Michael J. Sacksteder
`Michael J. Sacksteder
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