Data Scape Limited v. Box, Inc.

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

Declaration of Matt Behn

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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 MATT BEHN IN SUPPORT OF BOX, INC.'S MOTION TO TRANSFER VENUE Box, Inc., Defendant. I, Matt Behn, declare: 1. I am employed by Box, Inc. ("Box") in the position of Technical Support Engineer. I have been employed at Box since March 2018. 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 Redwood City, California. 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 "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. I am not responsible for the design, development, and operation of the Accused Box Products. My role focuses on customer support relating to the Box Platform. I generally do not perform work regarding Box for Enterprise/Business, Box for Individuals & Teams, Box Drive, and Box Sync. In addition, 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 decisions about implementing the features of any of the Accused Box Products and I am not aware of any such decisions being made by Box personnel based in the Austin, Texas office. 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. Malt Behn