Data Scape Limited v. Box, Inc.

Western District of Texas, txwd-6:2019-cv-00025

Affidavit Heidi L. Keefe

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION DATA SCAPE LIMITED, Civil Action No. 6:19-CV-00025-ADA Plaintiff, DECLARATION OF HEIDI L. KEEFE IN SUPPORT OF DEFENDANT BOX, INC.'S v. MOTION TO TRANSFER VENUE TO THE NORTHERN DISTRICT OF BOX, INC., CALIFORNIA Defendant. I, Heidi L. Keefe, declare: 1. I am a partner at Cooley LLP, counsel for Defendant Box, Inc. ("Box"). I make this declaration in support of the Defendant Box, Inc.'s Motion to Transfer Venue to the Northern District of California. If called upon to testify, I could and would competently testify thereto. 2. Attached hereto as Exhibit A is a true and correct printout of a LinkedIn profile of Satish Asok, available at https://www.linkedin.com/in/satishasok/ (last visited April 30, 2019). 3. Attached hereto as Exhibit B is a true and correct printout of a LinkedIn profile of Griffin Dorman, available at https://www.linkedin.com/in/griffindorman/ (last visited April 30, 2019). 4. Attached hereto as Exhibit C is a true and correct printout of a LinkedIn profile of Arnold Goldberg, available at https://www.linkedin.com/in/arnoldgoldberg/ (last visited April 30, 2019). 5. Attached hereto as Exhibit D is a true and correct printout of a LinkedIn profile of Matthew Self, available at https://www.linkedin.com/in/mself/ (last visited April 30, 2019). 6. Attached hereto as Exhibit E is a true and correct printout of a LinkedIn profile of Ritik Malhorta, available at https://www.linkedin.com/in/ritikmalhotra/ (last visited April 30, 2019). 7. Attached hereto as Exhibit F is a true and correct printout of a LinkedIn profile of Tanooj Luthra, available at https://www.linkedin.com/in/tanoojluthra/ (last visited April 30, 2019). 8. Attached hereto as Exhibit G is a true and correct printout of a LinkedIn profile of Sarat Ravi, available at https://www.linkedin.com/in/sarat-ravi/ (last visited April 30, 2019). 9. Attached hereto as Exhibit H is a true and correct printout of a LinkedIn profile of Neal Wu, available at https://www.linkedin.com/in/nealwu/ (last visited April 30, 2019). 10. Attached hereto as Exhibit I is a true and correct printout of a LinkedIn profile of Ketki Duvvuru (formerly Warudkar), available at https://www.linkedin.com/in/ketkiwarudkar/ (last visited April 30, 2019). 11. Attached hereto as Exhibit J is a true and correct printout of a Data Scape Limited full company view D&B credit report (last accessed April 8, 2019). 12. Attached hereto as Exhibit K is a true and correct printout of a LinkedIn profile of Gerald Padian, available at https://www.linkedin.com/in/geraldpadian (last visited April 8, 2019). 13. Attached hereto as Exhibit L is a true and correct printout of a LinkedIn profile of James Prusko, available at https://www.linkedin.com/in/prusko-jim-0279ba3 (last visited April 8, 2019). 14. Attached hereto as Exhibit M is a true and correct printout of a LinkedIn profile of Ciaran O'Gara, available at https://www.linkedin.com/in/ciaran-o-gara-6324b1147 (last visited April 8, 2019). 2 15. Attached hereto as Exhibit N is a true and correct printout of the Headquarters location for Box, Inc., available at https://www.box.com/about-us (last visited April 30, 2019). 16. Attached hereto as Exhibit O is a true and correct printout of the Headquarters location for Dropbox, Inc., available at https://www.headquartersinfo.com/dropbox-headquarters- information/ (last visited April 30, 2019). 17. Attached hereto as Exhibit P is a true and correct printout of the Headquarters location for Apple, Inc., available at https://www.apple.com/contact/ (last visited April 25, 2019). 18. Attached hereto as Exhibit Q is a true and correct printout of the Headquarters location for Western Digital Corp., available at https://www.craft.co/western-digital-corporation (last visited April 25, 2019). 19. Attached hereto as Exhibit R is a true and correct printout of the Headquarters location for Barracuda Networks, Inc., available at https://www.barracuda.com/company/contact (last visited April 25, 2019). 20. Attached hereto as Exhibit S is a true and correct printout of the Headquarters location for Pandora Media, Inc., available at https://craft.co/pandora (last visited April 25, 2019). 21. Attached hereto as Exhibit T is a true and correct printout of the patent face of issued U.S. Patent No. 7,720,929. 22. Attached hereto as Exhibit U is a true and correct printout of the patent face of issued U.S. Patent No. 7,617,537. 23. Attached hereto as Exhibit V is a true and correct printout of the patent face of issued U.S. Patent No. 8,386,581. 3 24. Attached hereto as Exhibit W is a true and correct printout of the patent face of issued U.S. Patent No. 9,715,893. I declare under penalty of perjury, under the laws of the United States, that the aforementioned is true and correct to the best of my knowledge. Executed this 3rd day of May, 2019 in Palo Alto, California. /s/ Heidi L. Keefe Heidi L. Keefe 4