Match Group, LLC v. Bumble Trading Inc.

Western District of Texas, txwd-6:2018-cv-00080

Affidavit Declaration of Idan Wallichman iso Badoo Trading Limiteds Motion to Di

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IN THE UNITED STATES DISTRICT COURT WESTERN DISTRICT OF TEXAS WACO DIVISION MATCH GROUP, LLC, Plaintiff, vs. BUMBLE TRADING, INC., BUMBLE HOLDING, LTD., BADOO TRADING LIMITED, MAGIC LAB CO., WORLDWIDE VISION LIMITED, BADOO LIMITED, BADOO SOFTWARE LIMITED, and BADOO TECHNOLOGIES LIMITED, Case No.: 6:18-cv-00080-ADA-JCM JURY TRIAL Defendants. BUMBLE TRADING, INC. and BUMBLE HOLDING, LTD., Cross-Plaintiffs, vs. MATCH GROUP, LLC and IAC/INTERACTIVE CORP., Cross-Defendants. DECLARATION OF IDAN WALLICHMAN IN SUPPORT OF DEFENDANT BADOO TRADING LIMITED'S MOTION TO DISMISS PLAINTIFF MATCH GROUP, LLC'S FOURTH AMENDED COMPLAINT I, Idan Wallichman hereby declare: 1. I am over eighteen years of age. I have personal knowledge of the facts set forth in this declaration and, if called to testify as a witness, could and would testify competently thereto. 2. I understand that this declaration will be submitted to the United States District Court Å¿ur the Western District of Texas and may be considered by that Court in support Defendant Badoo Trading Limited's ("Badoo Trading") Motion to Dismiss. 3. I am a director of Badoo Trading. 4. Badoo Trading is a company incorporated and registered to do business in the United Kingdom. 5. Badoo Trading has no headquarters and no places of business in the United States. 6. Badoo Trading is a parent company of Bumble Holding Limited ("Bumble Holding"). 7. Badoo Trading owns no property in Texas. 8. Badoo Trading leases no property in Texas. 9. Badoo Trading has no offices in Texas. Badoo Trading has no bank accounts in Texas. 11. Badoo Trading has no employees in Texas. Badoo Trading does not have contractors in Texas. Badoo Trading is not registered to do business in Texas. 14. Badoo Trading does not pay any taxes either to the State of Texas or to cities in Texas. 15. Badoo Trading does not have an agent for service of process in Texas. -1- 16. Badoo Trading does not market, or manage distribution of the Bumble app. 17. Badoo Trading does not retain any revenue from the Bumble app. 18. Badoo Trading never authorized a representative to travel to Texas to represent Badoo Trading in discussions regarding a potential acquisition of Bumble Trading, Inc. or Bumble Holding, Ltd. by Match Group, LLC. 19. It would be extremely burdensome for Badoo Trading to defend this action in Texas. All of Badoo Trading's potential witnesses are located outside of the United States. Additionally, none of Badoo Trading's files and records are located in Texas. 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, information, and belief. Executed on October 7, 2019, in Lonner un // Idan Wallichman 211662748