Data Scape Limited v. Box, Inc.

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

Declaration of Jason Pan

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IN THE LTNITED STATES DISTRICT COURT FOR THE V/ESTERN DISTRICT OF TEXAS WACO DIVISION Data Scape Limited, Civil Action No. 6: 19-CV-00025-ADA Plaintiff, DECLARATION OF JASON PAN IN suPPoRT OF BOX,INC.'S MOTION TO v TRANSFER VENUE Box, Inc., Defendant. I, Jason Pan, declare: 1. I am employed by Box, Inc. ("Box") and currently hold the position of Associate Software Engineer. I have been employed at Box since August 2016. I have personal knowledge of the facts set forth in this declaration. If called as a witness to testifu, I could and would testiff competently to those facts. I provide this declaration in support of Box's Motion to Transfer Venue. 2. I report to a manager at Box who is based in Redwood City, California. I work as part of a team of six Box employees, all of whom are based in Redwood City except for myself. 3. I am informed that the following Box products are at issue: Box Platform, Box for Enterprise/Business, Box for Individuals & Teams, Box Drive, and Box Sync (together the ooAccused Box Products"). 4. I understand that the plaintiff in this lawsuit has alleged that I have relevant knowledge regarding "Design, development, and operation of the accused products, including the use of the Box API in data synchronization functions." This statement is not an accurate description of my work or my knowledge in that I did not have any involvement with the original design or development of any of the Accused Box Products. As a result, I do not have any direct personal knowledge of the design and development work resulting in the introduction of the Accused Box Products. 5. Furthermore, I am not, and have not been, responsible for design and development of the features of any of the Accused Box Products. In my experience, Box personnel in Redwood City, Califomia have had that responsibility. I declare under penalty of perjury, under the laws of the United States, that the foregoing is true and correct to the best of my knowledge. Executed this 16th day of May,2019 in Redwood City, California. 2