Data Scape Limited v. Box, Inc.

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

Declaration of Kyle Croft

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FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION —_jData Scape Limited, Civil Action No. 6:19-CV-00025—ADA Plaintiff, DECLARATION OF KYLE CROFT IN SUPPORT OF BOX, INC.'S MOTION TO TRANSFER VENUE Box, Inc., Defendant. 1, Kyle Croft, declare: 1. I am employed by Box, Inc. ("Box") in the position of Solutions Architect. I have been employed at Box since June 2015. I have personal knowledge of the facts set forth in this declaration. If called as a witness to testify, I could and would testify 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 Austin, Texas but my team ultimately reports into management based in Redwood City, Califomia. 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 "Accused Box Products"). 4. I understand that the plaintiff in this lawsuit has alleged that I have relevant knowledge regarding "Sales, marketing, and customer demand for the accused products." This statement is not an accurate description of my work or my knowledge. I have not worked in the sales or marketing of the Accused Box Products. I also do not work on customer demand for the Accused Box Products. My work relates to services that may support customers, such as helping customers with deployment-related services. 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 15th day of May, 2019 in Austin, Texas. \K MW rofi