Data Scape Limited v. Box, Inc.

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

Declaration of Tyler Mitchell

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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 TYLER MITCHELL IN SUPPORT OF BOX, INC.'S MOTION TO TRANSFER VENUE Box, Inc., Defendant. I, Tyler Mitchell, declare: 1. I am employed by Box, Inc. ("Box") in the position of Staff Database Engineer. I have been employed at Box since September 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 cloud databases used by the accused products." This statement is not an accurate description of my work or my knowledge. I do not work on "cloud databases" or "cloud databases used by the accused products." In addition, I do not generally have detailed technical knowledge about the various specific features provided by the Accused Box Products. My work focuses on MySQL database operations and particularly infrastructure management and performance tuning. I would defer to others at Box regarding the technical structure and operation of the various features provided by the Accused Box Products. 5. In addition, I was not responsible for the original design or development of the features of the Accused Box Products. As a result, I do not have any direct personal knowledge of the design and development work on the features of the Accused Box Products. 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.