Data Scape Limited v. Box, Inc.

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

Declaration of Phillip Moore

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IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS WACO DIVISION Civil Action No. 6:19-CV-00025-ADA Data Scape Limited, Plaintiff, DECLARATION OF PHILLIP MOORE IN SUPPORT OF BOX, INC.'S MOTION TO TRANSFER VENUE V. Box, Inc., Defendant I, Phillip Moore, declare: 1. I am employed by Box, Inc. ("Box") in the position of Senior Staff Site Reliability Engineer. I have been employed at Box since January 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 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 system architecture supporting the accused products." This statement is not an accurate description of my work or my knowledge. The system architecture underlying the Accused Box Products includes server-side architecture (generally at Box's servers) and client-side architecture (generally at users' devices). I do not have detailed technical knowledge regarding either of those two areas. My work focuses on data traffic over networks. Generally the subject matter of my work and knowledge does not include knowledge about data or features that are specific to any of the Accused Box Products. I would defer to others for detailed technical knowledge about features specific to the Accused Box Products. 5. 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 on the Accused Box Products that resulted in their introduction. 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. Chittin Moore Phillip Moore