Case 4:23-cv-01147-ALM Document 32-1 Filed 06/17/24 Page 1 of 9 PageID #: 1052
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`Exhibit A
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`Exhibit A
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`Case 4:23-cv-01147-ALM Document 32-1 Filed 06/17/24 Page 2 of 9 PageID #: 1053
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`SHERMAN DIVISION
`
`
`
`
`Civil Action No. 4:23-cv-01147-ALM
`
`
`
`
`
`
`
`R2 Solutions LLC,
`
` Plaintiff,
`
`v.
`
`
`Databricks, Inc.,
`
` Defendant.
`
`
`
`
`
`DECLARATION OF CARDER W. BROOKS IN SUPPORT OF PLAINTIFF’S
`RESPONSE IN OPPOSITION TO DEFENDANT’S MOTION TO
`TRANSFER VENUE PURSUANT TO 28 U.S.C. § 1404(a)
`
`My name is Carder Brooks. I am over 18 years of age, of sound mind, and fully
`
`1.
`
`qualified and competent in all respects to make this declaration. The facts set forth in this
`
`declaration are based upon my personal knowledge and are true and correct.
`
`2.
`
`I am an attorney with the firm Nelson Bumgardner Conroy PC, which represents
`
`Plaintiff R2 Solutions LLC, in the above-captioned case. This declaration is submitted to support
`
`Plaintiff’s Response in Opposition to Defendant’s Motion to Transfer Venue pursuant to 28
`
`U.S.C. § 1404(a).
`
`3.
`
`Attached hereto as Exhibit 1 is a true and correct copy of a Court Comparison
`
`Report: EDTX vs. NDCA, Docket Navigator, accessed from and available at
`
`https://search.docketnavigator.com/patent/court_comparison/0/0 (last accessed June 6, 2024).
`
`4.
`
`Attached hereto as Exhibit 2 is a true and correct excerpt of the December 31,
`
`2023 Report for the Federal Court Management Statistics, downloaded from and available at
`
`1
`
`
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`Case 4:23-cv-01147-ALM Document 32-1 Filed 06/17/24 Page 3 of 9 PageID #: 1054
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`https://www.uscourts.gov/sites/default/files/fcms_na_distprofile1231.2023_0.pdf (last accessed
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`June 6, 2024).
`
`5.
`
`Attached hereto as Exhibit 3 is a true and correct copy of the Certificate of
`
`Formation Limited Liability Company for R2 Solutions, LLC filed in the Office of the Secretary
`
`of State of Texas.
`
`6.
`
`Attached hereto as Exhibit 4 is a true and correct copy of the Membership Interest
`
`Purchase Agreement executed on April 25, 2020.
`
`7.
`
`Attached hereto as Exhibit 5 is a true and correct copy of the results of a search
`
`for “R2 Solutions LLC” conducted on June 6, 2024, using the “Taxable Entity Search” engine at
`
`https://mycpa.cpa.state.tx.us/coa/ maintained by the Office of the Comptroller of Public
`
`Accounts of the State of Texas.
`
`8.
`
`Attached hereto as Exhibit 6 is a true and correct copy of the Certificate of Fact
`
`certified by the Secretary of State of Texas that the Certificate of Formation for R2 Solutions
`
`LLC was filed in the Office of the Secretary of State on May 16, 2016.
`
`9.
`
`Attached hereto as Exhibit 7 is a true and correct copy of a LinkedIn search for
`
`Databricks employees in Texas, accessed from and available at
`
`https://www.linkedin.com/search/results/people/?currentCompany=%5B%223477522%22%5D
`
`&geoUrn=%5B%22102748797%22%5D&origin=FACETED_SEARCH&sid=tj%2C (last
`
`accessed June 5, 2024).
`
`10.
`
`Attached hereto as Exhibit 8 is a true and correct copy of a LinkedIn search for
`
`Databricks employees in the Dallas-Fort Worth metroplex, accessed from and available at
`
`https://www.linkedin.com/search/results/people/?currentCompany=%5B%223477522%22%5D
`
`2
`
`
`
`Case 4:23-cv-01147-ALM Document 32-1 Filed 06/17/24 Page 4 of 9 PageID #: 1055
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`&geoUrn=%5B%2290000031%22%5D&origin=FACETED_SEARCH&sid=po~ (last accessed
`
`June 6, 2024).
`
`11.
`
`Attached hereto as Exhibit 9 is a true and correct copy of a LinkedIn search for
`
`Databricks employees in Plano, Texas, accessed from and available at
`
`https://www.linkedin.com/search/results/people/?currentCompany=%5B%223477522%22%5D
`
`&geoUrn=%5B%22100517351%22%5D&origin=FACETED_SEARCH&sid=8-h (last accessed
`
`June 5, 2024).
`
`12.
`
`Attached hereto as Exhibit 10 is a true and correct copy of a Databricks webpage
`
`accessed from and available at https://www.databricks.com/company/contact/office-locations
`
`(last accessed June 6, 2024).
`
`13.
`
`Attached hereto as Exhibit 11 is a true and correct copy of the LinkedIn profile
`
`for Giri R. Varatharajan, accessed from and available at
`
`https://www.linkedin.com/in/girivaratharajan/ (last accessed June 5, 2024).
`
`14.
`
`Attached hereto as Exhibit 12 is a true and correct copy of the LinkedIn profile
`
`for Amit Kumar Jha, accessed from and available at https://www.linkedin.com/in/akj/ (last
`
`accessed June 5, 2024).
`
`15.
`
`Attached hereto as Exhibit 13 is a true and correct copy of the LinkedIn profile
`
`for Archana Krishnamurthy, accessed from and available at
`
`https://www.linkedin.com/in/archana-krishnamurthy-073b7786/ (last accessed June 5, 2024).
`
`16.
`
`Attached hereto as Exhibit 14 is a true and correct copy of the LinkedIn profile
`
`for Birbal Das, accessed from and available at https://www.linkedin.com/in/birbal-das-
`
`a6a367195/ (last accessed June 5, 2024).
`
`3
`
`
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`Case 4:23-cv-01147-ALM Document 32-1 Filed 06/17/24 Page 5 of 9 PageID #: 1056
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`17.
`
`Attached hereto as Exhibit 15 is a true and correct copy of the LinkedIn profile
`
`for Cody Austin Davis, accessed from and available at
`
`https://www.linkedin.com/in/codydavis55/ (last accessed June 5, 2024).
`
`18.
`
`Attached hereto as Exhibit 16 is a true and correct copy of the LinkedIn profile
`
`for Hari Ganesan, accessed from and available at https://www.linkedin.com/in/hariharanganesan/
`
`(last accessed June 5, 2024).
`
`19.
`
`Attached hereto as Exhibit 17 is a true and correct copy of the LinkedIn profile
`
`for Hayley Horn, accessed from and available at https://www.linkedin.com/in/hayleyhorn/ (last
`
`accessed June 5, 2024).
`
`20.
`
`Attached hereto as Exhibit 18 is a true and correct copy of the LinkedIn profile
`
`for Howard W., accessed from and available at https://www.linkedin.com/in/howard-w-9912818/
`
`(last accessed June 5, 2024).
`
`21.
`
`Attached hereto as Exhibit 19 is a true and correct copy of the LinkedIn profile
`
`for Joshua Bae, accessed from and available at https://www.linkedin.com/in/joshua-bae/ (last
`
`accessed June 5, 2024).
`
`22.
`
`Attached hereto as Exhibit 20 is a true and correct copy of the LinkedIn profile
`
`for Jun Yang, accessed from and available at https://www.linkedin.com/in/junyangdev/ (last
`
`accessed June 5, 2024).
`
`23.
`
`Attached hereto as Exhibit 21 is a true and correct copy of the LinkedIn profile
`
`for Mathan Pillai, accessed from and available at https://www.linkedin.com/in/mathan-pillai-
`
`3b254961/ (last accessed June 5, 2024).
`
`4
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`
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`Case 4:23-cv-01147-ALM Document 32-1 Filed 06/17/24 Page 6 of 9 PageID #: 1057
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`24.
`
`Attached hereto as Exhibit 22 is a true and correct copy of the LinkedIn profile
`
`for Phanitha Kommareddi, accessed from and available at https://www.linkedin.com/in/phanitha-
`
`kommareddi-3ab563155/ (last accessed June 5, 2024).
`
`25.
`
`Attached hereto as Exhibit 23 is a true and correct copy of the LinkedIn profile
`
`for Scott Love, accessed from and available at https://www.linkedin.com/in/lovescott/ (last
`
`accessed June 5, 2024).
`
`26.
`
`Attached hereto as Exhibit 24 is a true and correct copy of the LinkedIn profile
`
`for Shyamprasad Reddy, accessed from and available at https://www.linkedin.com/in/shyamspr/
`
`(last accessed June 5, 2024).
`
`27.
`
`Attached hereto as Exhibit 25 is a true and correct copy of the LinkedIn profile
`
`for Srikanth Gupta Anumula, accessed from and available at
`
`https://www.linkedin.com/in/srikanth-gupta-anumula-4a215416/ (last accessed June 5, 2024).
`
`28.
`
`Attached hereto as Exhibit 26 is a true and correct copy of the LinkedIn profile
`
`for Stephen Hage, accessed from and available at https://www.linkedin.com/in/stephenhage/ (last
`
`accessed June 5, 2024).
`
`29.
`
`Attached hereto as Exhibit 27 is a true and correct copy of the LinkedIn profile
`
`for Suraj Karuvel, accessed from and available at https://www.linkedin.com/in/surajkaruvel/ (last
`
`accessed June 5, 2024).
`
`30.
`
`Attached hereto as Exhibit 28 is a true and correct copy of the LinkedIn profile
`
`for Tanveer Shaikh, accessed from and available at https://www.linkedin.com/in/tanveer-shaikh-
`
`12467363/ (last accessed June 5, 2024).
`
`5
`
`
`
`Case 4:23-cv-01147-ALM Document 32-1 Filed 06/17/24 Page 7 of 9 PageID #: 1058
`
`31.
`
`Attached hereto as Exhibit 29 is a true and correct copy of the LinkedIn profile
`
`for Vasu, accessed from and available at https://www.linkedin.com/in/sreenids/ (last accessed
`
`June 5, 2024).
`
`32.
`
`Attached hereto as Exhibit 30 is a true and correct copy of the LinkedIn profile
`
`for Yedunathan Ambileriveettil, accessed from and available at
`
`https://www.linkedin.com/in/yedunathan-ambileriveettil-b6706723/ (last accessed June 5, 2024).
`
`33.
`
`Below is a table summarizing the LinkedIn profiles of Databricks employees:
`
`Employee
`Giri R.
`Varatharajan
`
`(Ex. 11)
`
`Amit Kumar
`Jha
`
`(Ex. 12)
`
`Archana
`Krishnamurthy
`
`(Ex. 13)
`
`Birbal Das
`
`(Ex. 14)
`
`Cody Austin
`Davis
`
`(Ex. 15)
`
`Hari Ganesan
`
`(Ex. 16)
`
`Hayley Horn
`
`
`Title
`Director,
`Technical
`Solutions
`
`Solutions
`Architect,
`Delivery
`
`Delivery
`Solutions
`Architect
`
`Sr. Specialist
`Solution
`Architect
`
`Sr. Solutions
`Architect –
`Digital Native
`Business,
`Strategic
`Accounts
`Senior Resident
`Solutions
`Architect
`
`Field
`Engineering
`
`Location
`DFW Metroplex
`
`
`Relevant Knowledge
`Spark, Databricks Platform (leads
`technical solutions team)
`
`
`DFW Metroplex
`
`Spark, Databricks Platform
`
`
`
`DFW Metroplex
`
`Spark, Databricks Platform,
`customer use cases and inducement
`
`DFW Metroplex
`
`Spark, Databricks Platform
`
`DFW Metroplex
`
`
`Spark, Databricks Platform,
`Lakehouse ecosystem (leads the
`Data Warehousing SME group)
`
`Plano, TX
`
`
`Spark, Databricks Platform,
`customer use cases and inducement
`
`Plano, TX
`
`Spark, Databricks Platform
`
`6
`
`
`
`Case 4:23-cv-01147-ALM Document 32-1 Filed 06/17/24 Page 8 of 9 PageID #: 1059
`
`(Ex. 17)
`
`Howard W.
`
`(Ex. 18)
`
`Manager
`
`Senior Solutions
`Architect
`
`Plano, TX
`
`Senior Delivery
`Solutions
`Engineer
`
`Plano, TX
`
`
`Spark, Databricks Platform, Big
`Data Analytics (spearheaded
`Spark/Databricks certification
`program for those who “wanted
`deeper technical knowledge on
`Spark programming”)
`Spark, Databricks Platform
`
`Joshua Bae
`
`(Ex. 19)
`
`
`Jun Yang
`
`(Ex. 20)
`
`
`Mathan Pillai
`
`(Ex. 21)
`
`Phanitha
`Kommareddi
`
`(Ex. 22)
`Scott Love
`
`(Ex. 23)
`
`
`Shyamprasad
`Reddy
`
`(Ex. 24)
`
`
`Srikanth Gupta
`Anumula
`
`(Ex. 25)
`
`
`Stephen Hage
`
`(Ex. 26)
`
`Sr. Technical
`Solutions
`Engineer
`
`BigData
`Solutions
`Engineer
`
`Delivery
`Solutions
`Architect
`
`Practice Lead –
`Resident
`Solutions
`Architect
`
`Senior Solutions
`Engineer
`
`Resident
`Solutions
`Architect
`
`Solutions
`Architect
`
`DFW Metroplex
`
`
`Spark, Databricks Platform
`
`
`Plano, TX
`
`
`Leander, TX
`
`Spark, Databricks Platform (expert
`in field), customer use cases and
`inducement
`
`Spark, Databricks Platform,
`customer use cases and inducement
`
`Plano, TX
`
`Spark, Databricks Platform
`
`Plano, TX
`
`Spark, Databricks Platform
`
`
`Plano, TX
`
`
`
`Spark, Databricks Platform, Big
`Data Analytics
`
`DFW Metroplex
`
`Spark, Databricks Platform
`
`7
`
`
`
`Case 4:23-cv-01147-ALM Document 32-1 Filed 06/17/24 Page 9 of 9 PagelD #: 1060
`
`
`
`Suraj Karuvel|Solutions DFW Metroplex Spark, Databricks Platform
`
`Architect — Field
`Engineering
`
`(Ex, 27)
`
`
`Tanveer
`Sr. Manager,
`DFW Metroplex
`Spark, Databricks Platform
`Shaikh
`Field
`Engineering
`
`(Ex. 28)
`
`Vasu
`Sr. Python
`Plano, TX; San
`Spark, Databricks Platform,
`Developer
`Francisco, CA
`MapReduce
`
`
`
`
`
`
`
`(Ex. 29)
`Spark, Databricks Platform, Data
`Plano, TX
`Delivery
`Yedunathan
`
`Ambileriveettil|Solutions Science
`Architect
`
`(Ex. 30)
`
`34.
`
`Substantially all, if not all, of R2 Solutions LLC’s documents are stored on
`
`servers at our offices located in Fort Worth, Texas. Such documents include information relevant
`
`to patent prosecution, ownership, infringement, damages(such as license agreements involving
`
`the asserted patents), and validity (including variousasserted priorart). To the best of my
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`knowledge, no physical copies of these documentsare located in California.
`
`I declare underpenalty of perjury that the statements made in this Declaration are true
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`and correct.
`
`Dated: June 10, 2024
`
`
`
`Carder W. Brooks
`
`
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