`DATABRICKS, INC.,
`
`
`v.
`
`Defendant.
`
`
`
`
`
`Case 4:23-cv-01147-ALM Document 22-3 Filed 05/23/24 Page 1 of 6 PageID #: 430
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
`
`R2 SOLUTIONS LLC,
`
`
`Plaintiff,
`
`Civil Action No. 4:23-cv-01147-ALM
`
`JURY TRIAL DEMANDED
`
`
`
`DECLARATION OF JESSICA M. KAEMPF IN SUPPORT OF
`DATABRICKS, INC.’S MOTION TO TRANSFER VENUE TO THE
`NORTHERN DISTRICT OF CALIFORNIA PURSUANT TO 28 U.S.C. § 1404(a)
`
`
`
`
`
`
`
`
`Case 4:23-cv-01147-ALM Document 22-3 Filed 05/23/24 Page 2 of 6 PageID #: 431
`
`I, Jessica M. Kaempf, declares as follows:
`
`1.
`
`I am an attorney admitted to this Court, and I am an associate of the law firm of
`
`Fenwick and West LLP, counsel of record for Defendant Databricks, Inc. (“Databricks”) in this
`
`action. I make this declaration in support of Databricks’s Motion to Transfer Venue Pursuant to
`
`28 U.S.C. § 1404(a).
`
`2.
`
`Attached hereto as Exhibit A is a true and correct annotated printout of an
`
`Internet Archive capture of a Yahoo! Inc. webpage on October 6, 2006, which was obtained from
`
`https://web.archive.org/web/20061006145034/http://docs.yahoo.com:80/info/address/.
`
`3.
`
`Attached hereto as Exhibit B is a true and correct annotated copy of the LinkedIn
`
`page for Ali Dasdan, which was obtained from https://www.linkedin.com/in/dasdan/.
`
`4.
`
`Attached hereto as Exhibit C is a true and correct annotated copy of the LinkedIn
`
`page for Ruey-Lung Hsiao, which was obtained from https://www.linkedin.com/in/ruey-lung-
`
`hsiao-5a85a06/.
`
`5.
`
`Attached hereto as Exhibit D is a true and correct annotated copy of the LinkedIn
`
`page for Hung-chih Yang, which was obtained from https://www.linkedin.com/in/hung-chih-
`
`yang-4a8a647/.
`
`6.
`
`Attached hereto as Exhibit E is a true and correct annotated copy of the assignment
`
`history of the ’610 patent, which was obtained from
`
`https://patentcenter.uspto.gov/applications/11539090/assignments?application=.
`
`7.
`
`Attached hereto as Exhibit F is a true and correct annotated copy of Exhibit 10 to
`
`the Declaration of Eric Lucas dated May 19, 2021 filed in the case, R2 Solutions LLC v. Target
`
`Corp., Case No. 4:21-cv-00092-ALM (E.D. Tex.).
`
`8.
`
`Attached hereto as Exhibit G is a true and correct annotated copy of the LinkedIn
`
`page for Eric Lucas, which was obtained from https://www.linkedin.com/in/eric-lucas-29a0232a.
`
`1
`
`
`
`Case 4:23-cv-01147-ALM Document 22-3 Filed 05/23/24 Page 3 of 6 PageID #: 432
`
`9.
`
`Attached hereto as Exhibit H is a true and correct annotated copy of the LinkedIn
`
`page for Jeffrey Dean, one of the creators of MapReduce, which was obtained from
`
`https://www.linkedin.com/in/jeff-dean-8b212555/.
`
`10.
`
`Attached hereto as Exhibit I is a true and correct, annotated and excerpted copy of
`
`the Accurint report for Sanjay Ghemawat.
`
`11.
`
`Attached hereto as Exhibit J is a true and correct copy of the U.S. Patent No.
`
`7,590,620.
`
`12.
`
`Attached hereto as Exhibit K is a true and correct copy of the US Patent Publication
`
`No. 2006/0218123.
`
`13.
`
`Attached hereto as Exhibit L is a true and correct copy of the U.S. Patent No.
`
`6,343,295.
`
`14.
`
`Attached hereto as Exhibit M is a true and correct, annotated and excerpted copy of
`
`the Accurint report for Robert Charles Pike.
`
`15.
`
`Attached hereto as Exhibit N is a true and correct annotated copy of the LinkedIn
`
`page for Sean Quinlan, which was obtained from https://www.linkedin.com/in/sean-quinlan-
`
`8051a3/.
`
`16.
`
`Attached hereto as Exhibit O is a true and correct copy of the LinkedIn page for
`
`Sudipto Chowdhuri, which was obtained from https://www.linkedin.com/in/sudipto-chowdhuri-
`
`b00b9021/.
`
`17.
`
`Attached hereto as Exhibit P is a true and correct annotated copy of the LinkedIn
`
`page for Casey L. Kiernan, which was obtained from
`
`https://www.linkedin.com/in/caseykiernan/details/experience/.
`
`18.
`
`Attached here to as Exhibit Q is a true and correct annotated copy of the
`
`Certificate of Amendment filed by R2 with the Secretary of State for the State of Texas.
`
`2
`
`
`
`Case 4:23-cv-01147-ALM Document 22-3 Filed 05/23/24 Page 4 of 6 PageID #: 433
`
`19.
`
`Attached hereto as Exhibit R is a true and correct annotated copy of the LinkedIn
`
`page for Marc Booth, a signatory of R2’s filings to the Texas Secretary of State.
`
`20.
`
`Attached hereto as Exhibit S is a true and correct annotated copy of the LinkedIn
`
`page for Acacia Research Group LLC, which was obtained from
`
`https://www.linkedin.com/company/acacia-research-group-llc/people/.
`
`21.
`
`Attached hereto as Exhibit T is a true and correct annotated copy of Acacia
`
`Research Corporation’s “contact us” webpage, which is available at
`
`https://www.acaciaresearch.com/#ContactUs.
`
`22.
`
`Attached hereto as Exhibit U is a true and correct annotated copy of the
`
`management list for Acacia Research Group LLC downloaded from the Texas Secretary of State
`
`website.
`
`23.
`
`Attached hereto as Exhibit V is a true and correct annotated copy of a Google
`
`Maps image showing the distance from Databricks’ headquarters to the Eastern District of Texas,
`
`Sherman Division.
`
`24.
`
`Attached hereto as Exhibit W is a true and correct copy of a Google Maps image
`
`showing the distance from Laguna Beach, California to Sherman, Texas.
`
`25.
`
`Attached hereto as Exhibit X is a true and correct copy of a Google Maps image
`
`showing the distance from Laguna Beach, California to San Francisco, California.
`
`26.
`
`Attached hereto as Exhibit Y is a true and correct annotated and excerpted copy of
`
`the Accurint report for Sean M. Dorward.
`
`27.
`
`Attached hereto as Exhibit Z is a true and correct annotated copy of the LinkedIn
`
`page for Steward P. MacLeod, which was obtained from
`
`https://www.linkedin.com/in/directorsoftwaredevelopment/.
`
`3
`
`
`
`Case 4:23-cv-01147-ALM Document 22-3 Filed 05/23/24 Page 5 of 6 PageID #: 434
`
`28.
`
`Attached hereto as Exhibit AA is a true and correct copy of the LinkedIn page for
`
`Vij Rajaraian, which was obtained from https://www.linkedin.com/in/vijrajarajan/.
`
` I
`
` declare under penalty of perjury under the laws of the United States of America that, to
`
`the best of my belief, the foregoing is true and correct, and that this Declaration was executed on
`
`May 21, 2024.
`
`
`Jessica M. Kaempf
`
`
`
`4
`
`
`
`Case 4:23-cv-01147-ALM Document 22-3 Filed 05/23/24 Page 6 of 6 PageID #: 435
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that all counsel of record who are deemed to have consented to electronic
`
`service are being served with a copy of this document via the Court’s CM/ECF system per Local
`
`Rule CV-5(a)(3) on May 21, 2024. Additionally, I hereby certify that all counsel of record who
`
`consented to electronic service are being served with a copy of this document via electronic mail
`
`per Local Rule CV-5.
`
`/s/ Michael J. Sacksteder
`Michael J. Sacksteder
`
`5
`
`
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