Case 6:21-cv-00667-ADA Document 59-1 Filed 05/13/22 Page 1 of 5
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
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`VOIP-PAL.COM, INC.,
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`Plaintiff
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`v.
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`GOOGLE LLC,
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`Defendants.
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`CASE NO. 6:21-cv-00667-ADA
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`JURY TRIAL DEMANDED
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`DECLARATION OF ROBERT W. UNIKEL IN SUPPORT OF THE REPLY
`IN SUPPORT OF DEFENDANT GOOGLE LLC’S
`OPPOSED MOTION TO TRANSFER
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`PUBLIC VERSION
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`VOIP-PAL.COM, INC.,
`
`Plaintiff
`
`v.
`
`GOOGLE LLC,
`
`Defendants.
`
`
`
`CASE NO. 6:21-cv-00667-ADA
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`JURY TRIAL DEMANDED
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`§
`§
`§
`§
`§
`§
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`§
`§
`§
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`DECLARATION OF ROBERT W. UNIKEL IN SUPPORT OF THE REPLY
`IN SUPPORT OF DEFENDANT GOOGLE LLC’S
`OPPOSED MOTION TO TRANSFER
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`PUBLIC VERSION
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`Case 6:21-cv-00667-ADA Document 59-1 Filed 05/13/22 Page 2 of 5
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`I, Robert W. Unikel, declare as follows:
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`1.
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`I am an attorney with the law firm Paul Hastings LLP and counsel for Defendant
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`Google LLC (“Google”). I have personal knowledge of the facts contained in the declaration and,
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`if called upon to do so, I could and would testify competently to the matters set forth herein.
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`2.
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`During venue discovery in this case, VoIP-Pal asked Google to provide
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`“[d]ocuments sufficient to show Google’s organizational structure[.]” After meeting and
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`conferring to resolve disputes, Google produced charts indicating direct reports of certain
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`individuals as well as who those individuals report to.
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`3.
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`In VoIP-Pal’s responses and objections
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`to Google LLC’s venue-related
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`interrogatories, in response to an interrogatory asking for the “Percentage of Time at Office
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`Location” that Mr. Kevin Williams spends in Waco, Texas, VoIP-Pal responded “[p]art time in
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`Waco office[.]”
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`4.
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`In Google’s February 28, 2022 objections and responses to VoIP-Pal’s
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`interrogatories for venue purposes, Google repeatedly confirmed that
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`5.
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`Attached hereto as Exhibit 1 is a true and correct copy of a Liberty Virtual Office
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`Application signed on behalf of VoIP-Pal.Com Inc. on May 15, 2020 as produced to Defendant
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`bearing Bates numbers VOP-GOOGLE0000031–33.
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`Case 6:21-cv-00667-ADA Document 59-1 Filed 05/13/22 Page 3 of 5
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`6.
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`Attached hereto as Exhibit 2 is a true and correct copy of a Liberty Virtual Office
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`Application signed on behalf of VoIP-Pal.Com Inc. on May 15, 2020 as produced to Defendant
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`bearing Bates numbers VOP-GOOGLE0000034–36.
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`7.
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`Attached hereto as Exhibit 3 is a true and correct copy of VoIP-Pal’s Initial
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`Disclosures under Fed. R. Civ. P. 26(a)(1) served in Cellco Partnership dba Verizon Wireless et
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`al., v. VoIP-Pal.com, Inc., No. 3:21-cv-05275 (N. D. Cal.), dated October 7, 2021, as produced to
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`Defendant bearing Bates numbers VOP-GOOGLE0000009–15, which states on page 4 that VoIP-
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`Pal maintains certain documents in Mountain View, CA.
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`8.
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`Attached hereto as Exhibit 4 is a true and correct copy of VoIP-Pal’s Initial
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`Disclosures under Fed. R. Civ. P. 26(a)(1) served in AT&T Corp. et al., v. VoIP-Pal.com, Inc., No.
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`3:21-cv-05078 (N.D. Cal.), dated October 7, 2021, as produced to Defendant bearing Bates
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`numbers VOP-GOOGLE0000016–23, which states on page 4 that VoIP-Pal maintains certain
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`documents in Mountain View, CA.
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`9.
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`Attached hereto as Exhibit 5 is a true and correct copy of VoIP-Pal’s Initial
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`Disclosures under Fed. R. Civ. P. 26(a)(1) served in Apple Inc., v. VoIP-Pal.com, Inc., No. 3:21-
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`cv-05110 (N.D. Cal.), dated October 7, 2021, as produced to Defendant bearing Bates numbers
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`VOP-GOOGLE0000024–30, which states on page 4 that VoIP-Pal maintains certain documents
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`in Mountain View, CA.
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`10.
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`Attached hereto as Exhibit 6 is a true and correct copy of an agreement between
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`VoIP-Pal and Business Legal Management LLC dated June 10, 2019, as produced to Defendant
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`bearing Bates numbers VOP-GOOGLE0000001–4.
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`Case 6:21-cv-00667-ADA Document 59-1 Filed 05/13/22 Page 4 of 5
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`11.
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`Attached hereto as Exhibit 7 is a true and correct copy of an agreement between
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`VoIP-Pal and Business Legal Management LLC dated February 18, 2019, as produced to
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`Defendant bearing Bates numbers VOP-GOOGLE0000005–8.
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`12.
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`Attached hereto as Exhibit 8 is a true and correct copy of a document entitled
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`“Business Legal Management + VoIP-Pal Introduction of Principals” dated January 21, 2019, as
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`produced to Defendant bearing Bates numbers VOP-GOOGLE0000037–42.
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`13.
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`Attached hereto as Exhibit 9 is a true and correct copy of an agreement between
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`VoIP-Pal and Intellion Analytics Group dated February 8, 2019, as produced to Defendant bearing
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`Bates numbers VOP-GOOGLE0000058–62.
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`14. Magistrate Judge Virginia K. DeMarchi was referred to actions concerning VoIP-
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`Pal and its patent portfolio with the following N.D. Cal. case numbers, according to their headers
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`and/or dockets on Docket Navigator: 5:18-cv-06217; 5:18-cv-06054; 5:18-cv-06177; 5:18-cv-
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`04523; 5:18-cv-07020; 5:18-cv-06216; 5:20-cv-02460; 5:20-cv-03092; 5:20-cv-02995; 3:20-cv-
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`02397; and 3:21-cv-09773.
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`15.
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`The Cellco Partnership dba Verizon Wireless et al., v. VoIP-Pal.com, Inc., No.
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`3:21-cv-05275 (N. D. Cal.) and Twitter, Inc. v. VoIP-Pal.Com, Inc., No. 3:21-cv-09773 (N. D.
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`Cal.) cases relate to U.S. Patent Nos. 10,880,721 and 8,630,234 and are actively presided over by
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`Judge James Donato.
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`16.
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`Exhibit 10 is a true and correct copy of a webpage from Lex Machina regarding
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`Judge Alan D. Albright.
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`17.
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`Exhibit 11 is a true and correct copy of a webpage from Lex Machina regarding
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`Judge James Donato.
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`Case 6:21-cv-00667-ADA Document 59-1 Filed 05/13/22 Page 5 of 5
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`18.
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`Exhibit 12 is a true and correct copy of a webpage from Lex Machina regarding
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`Judge Virginia K. DeMarchi.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed this 6th
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`day of May in Chicago, Illinois.
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`/s/ Robert W. Unikel
`Robert W. Unikel
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`PUBLIC VERSION
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