Data Scape Limited v. Dropbox, Inc.

Western District of Texas, txwd-6:2019-cv-00023

Affidavit of Paul A Kroeger

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UNITED STATES DISTRICT COURT IN THE WESTERN DISTRICT OF TEXAS WACO DIVISION DATA SCAPE LIMITED, C.A. No. 6:19-cv-00023-ADA Plaintiff, v. JURY TRIAL DEMANDED DROPBOX, INC., Defendant. DECLARATION OF PAUL A. KROEGER IN SUPPORT OF PLAINTIFF DATA SCAPE LIMITED'S OPPOSITION TO DEFENDANT DROPBOX, INC.'S TRANSFER VENUE TO THE NORTHERN DISTRICT OF CALIFORNIA 1 I, Paul A. Kroeger, state as follows: 1. I am a partner at the law firm of Russ August & Kabat, counsel for Plaintiff Data Scape Limited ("Data Scape") in this action, and a member in good standing of the bar of California. I make all statements herein based on my personal knowledge. 2. Attached hereto as Exhibit A is a true and correct copy of a printout of the LinkedIn profile of Edgar Aguillon, located at https://www.linkedin.com/in/edgar- aguillon/ (last visited May 8, 2019). 3. Attached hereto as Exhibit B is a true and correct copy of a printout of the LinkedIn profile of Rachel Belkin, located at https://www.linkedin.com/in/rachelbelkin/ (last visited May 8, 2019). There is a hyperlink to a video named "Dropbox Smart Sync: Work without limits" located under the "Enterprise Sales Manager" entry of Ms. Belkin's profile: 4. Attached hereto as Exhibit C is a true and correct copy of a printout of the LinkedIn profile of Alex Carp, located at https://www.linkedin.com/in/alexcarp (last 2 visited May 8, 2019). 5. Attached hereto as Exhibit D is a true and correct copy of a printout of the LinkedIn profile of Mike Roeder, located at https://www.linkedin.com/in/mcroeder/ (last visited May 8, 2019). 6. Attached hereto as Exhibit E is a true and correct copy of a printout the LinkedIn profile of Drew Betzer, located at https://www.linkedin.com/in/drewbetzer/ (last visited May 8, 2019). 7. Attached hereto as Exhibit F is a true and correct copy of a printout the LinkedIn profile of Meghan Sayers, located at https://www.linkedin.com/in/meghan- sayers-56292a2/ (last visited May 8, 2019). 8. Attached hereto as Exhibit G is a true and correct copy of a printout the LinkedIn profile of Jim Stagg, located at https://www.linkedin.com/in/jim-stagg- 43888738/ (last visited May 8, 2019). 9. Attached hereto as Exhibit H is a true and correct copy of an excerpt from the S-1 filing of Dropbox dated February 23, 2018, accessible at https://dropbox.gcs- web.com/static-files/12ef87e3-9175-4786-8efb-274888ca66da (last visited May 8, 2019). 10. Attached hereto as Exhibit I is a true and correct copy of an excerpt from the 10-K filing of Dropbox dated February 25, 2019, accessible at https://dropbox.gcs- web.com/static-files/a1ebb72d-7ef6-4b8e-bd91-71823a341fa7 (last visited May 8, 2019). 11. My review of the publicly-available patent prosecution file histories of U.S. Patents Nos. 7,720,929; 7,617,537; 8,386,581; and 9,715,893 (the "Asserted Patents") shows two law firms have been involved in the prosecution of those Asserted Patents: (1) Kramer & Amado, P.C.; and (2) Oblon, McClelland, Maier & Neustadt, 3 L.L.P. Based on my review of the websites of these law firms, respectively http://www.krameramado.com and https://www.oblon.com, I understand the offices and attorneys of these law firms to be primarily in Alexandria, Virginia. 12. My review of the public assignment histories of the Asserted Patents shows the following law firms have been involved in those assignments: (1) Cooper & Dunham LLP; (2) Kramer & Amado, P.C.; and (3) Fishman Stewart (f/k/a Rader Fishman & Grauer). Based on my review of the websites of Cooper & Dunham LLP (https://www.cooperdunham.com/) and Fishman Stewart (http://fishstewip.com/), I understand the offices and attorneys of these law firms are located in New York, New York; Bloomfield Hills, Michigan; and Washington, D.C. I declare under penalty of perjury that the foregoing is true and correct. Executed in Los Angeles, California on May 8, 2019. /s/ Paul A. Kroeger Paul A. Kroeger 4