`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`TYLER DIVISION
`
`C.A. No.: 6:12-cv-00799-LED
`
`JURY TRIAL DEMANDED
`
`§§
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`§
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`§§
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`§
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`INVENSYS SYSTEMS, INC.
`
`v.
`
`Plaintiff,
`
`EMERSON ELECTRIC CO. and
`MICRO MOTION INC., USA,
`
`Defendants.
`
`DECLARATION OF CLAUDIA W. FROST
`
`I, Claudia W. Frost, do hereby declare as follows:
`
`1. The exhibits listed below and attached to Plaintiff Invensys Systems, Inc.’s
`(“Invensys”) Response to Defendant Micro Motion Inc., USA’s (“Micro
`Motion”) Motion to Transfer Venue Pursuant to 28 U.S.C. § 1404(a) are true
`and correct copies of materials that I or one of my representatives printed
`from the Internet on February 7, 2013 (unless otherwise indicated):
`
`(a) Defendant Emerson Electric Co.
`2. Exhibit C (three documents):
`(“Emerson”), “Emerson Businesses,” emerson.com/en-US/about/emerson-
`businesses/Pages/default.aspx; (b) Emerson Process Management, “Micro
`Motion Coriolis Flow & Density Measurement,” emersonprocess.com/en-
`US/brands/micromotion/Pages/coriolis-flow-density-measurement.aspx;
`(c) Emerson
`Process Management,
`“Global
`Training
`Centers,”
`emersonprocess.com/en-
`US/brands/edservices/globaltrainingcenters/nacontacts/Pages/nacontacts.aspx.
`
`I&VS
`“New
`Controls,
`Scallon
`D:
`3. Exhibit
`scalloncontrols.com/announcements/new-i-vs-repair-center.
`
`Repair
`
`Center,”
`
`4. Exhibit E—Eric Fox, Bubbling Crude: America’s Top 6-Oil Producing States
`(June
`8,
`2011),
`msnbc.msn.com/id/43085246/ns/business-
`oil_and_energy/t/bubbling-crude-americas-top-oil-producing-states/.
`
`“Crude Oil Production,”
`5. Exhibit F—U.S. Energy Info. Admin.,
`eia.gov/dnav/pet/pet_crd_crpdn_adc_mbbl_m.htm (click “Texas”).
`
`6. Exhibit G—U.S. Energy Info. Admin., “Rankings: Crude Oil Production,
`September 2012,” eia.gov/beta/state/rankings/?sid=US#/series/46.
`
`
`
`Case 6:12-cv-00799-JRG Document 26-2 Filed 02/11/13 Page 2 of 2 PageID #: 1188
`
`7. Exhibit H—U.S. Energy Info. Admin., “Rankings: Natural Gas Marketed
`Production, 2011,” eia.gov/beta/state/rankings/?sid=US#/series/47.
`
`8. Exhibit I—Kate Galbraith, Boom Promises 20,000 New Jobs but Shortages
`Too, N.Y. TIMES, July 15, 2012, at A23.
`
`J—U.S. Energy Info. Admin.,
`9. Exhibit
`eia.gov/petroleum/refinerycapacity/.
`
`“Refinery Capacity Report,”
`
`10. Exhibit K—Warren R. True, Asia, Middle East Lead Modest Recovery in
`Global Refining, OIL & GAS J., Dec. 3, 2012, at 32.
`
`11. Exhibit L—U.S. Energy Info. Admin., “U.S. Refineries Operable Capacity,”
`eia.gov/energyexplained/index.cfm?page=oil_refining#tab4.
`
`12. Exhibit M (three documents)—(a) Emerson Process Mgmt., “Sales Rep Flow
`Products—Houston Ship Channel,” linkedin.com/jobs/jobs-Sales-Rep-Flow-
`4136439;
`(b)
`Emerson
`Process Mgmt.,
`“Sales
`Representative
`(Measurement)—Houston
`Contractor
`Group,”
`linkedin.com/jobs?viewJob=&jobId=4136444; (c) Emerson Process Mgmt.,
`“Flow Measurement Specialist,” (formerly on LinkedIn, but since removed)
`(printed on January 14, 2013).
`
`13. Exhibit O—Office of the Assistant Sec’y for Aviation & Int’l Affairs, U.S.
`Dept. of Transp., U.S. International Air Passenger and Freight Statistics, tab.
`6 (June 2012), dot.gov/policy/aviation-policy/us-international-air-passenger-
`and-freigh-statistics-report.
`
`“API Member
`Petroleum Inst.,
`P—Am.
`14. Exhibit
`api.org/globalitems/globalheaderpages/membership/api-member-
`companies.aspx (excerpts of relevant materials) (printed February 11, 2013).
`
`Companies,”
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated: February 11, 2013
`
`_____________________________________
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