Ixi Mobile (R&D) Ltd. et al v. Apple, Inc.

Northern District of California, cand-4:2015-cv-03755

DECLARATION of Steve Pedersen in Opposition re: 27 MOTION to Transfer Case Apple Inc.'s Notice of Motion to Transfer Venue Pursuant to 28 U.S.C. § 1404(a). Document filed by IXI IP,LLC, IXI Mobile (R&D) Ltd.

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UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF NEW YORK IXI MOBILE (R&D), LTD., et al., Plaintiffs, No. 14-cv-4355 (RJS) -v- SAMSUNG ELECTRONICS CO., et al., Defendants. IXI MOBILE (R&D), LTD., et al., Plaintiffs, No. 14-cv-4428 (RJS) -v- BLACKBERRY, LTD., et al., Defendants. IXI MOBILE (R&D), LTD., et al., Plaintiffs, No. 14-cv-7954 (RJS) -v- APPLE INC., Defendant. DECLARATION OF STEVE PEDERSEN I, Steve Pedersen, declare as follows: 1. I am the Principal and Manager of IXI IP, LLC ("IXI IP") ― one of the plaintiffs in the above actions. IXI IP is a New York limited liability company with its principal office in 118063893_1 the Chrysler Building at 405 Lexington Avenue, New York, New York 10174. IXI IP uses this office to conduct meetings and other business in New York City. 2. IXI IP entered into an agreement with IXI Mobile (R&D), Ltd. ("IXI Mobile") whereby IXI IP obtained ownership of the Patents-in-Suit. IXI IP then exclusively licensed the Patents-in-Suit to IXI Mobile. 3. IXI IP and IXI Mobile are trusted business partners, and while the two entities work cooperatively in the prosecution of the above actions, IXI IP is responsible for overseeing the litigation. 4. IXI IP chose to file suit in the Southern District of New York for a variety of reasons, including the fact that it is located in this district, and its chosen counsel has an office here. 5. IXI IP commenced the above actions in this forum out of considerations of cost and convenience, rather than for tactical reasons. 6. IXI IP retains documents related to the above actions at its offices in New York. I declare under penalty of perjury that the foregoing is true and correct to the best of my information, knowledge and belief. /s/ Steve Pedersen Steve Pedersen Dated: February 17, 2015 2 118063893_1