Match Group, LLC v. Bumble Trading Inc.

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

Affidavit Declaration of Luke Frendo iso Badoo Software Limiteds Motion to Dismi

Interested in this case?

Current View

Full Text

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 Defendants. JURY TRIAL BUMBLE TRADING, INC. and BUMBLE HOLDING, LTD., Cross-Plaintiffs, vs. MATCH GROUP, LLC and IAC/INTERACTIVE CORP., Cross-Defendants. DECLARATION OF LUKE FRENDO IN SUPPORT OF DEFENDANT BADOO SOFTWARE LIMITED'S MOTION TO DISMISS PLAINTIFF MATCH GROUP, LLC'S FOURTH AMENDED COMPLAINT I, Luke Frendo 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 for the Western District of Texas and may be considered by that Court in support Defendant Badoo Software Limited's ("Badoo Software") Motion to Dismiss. 3. I am a director of Badoo Software. 4. Badoo Software is a company incorporated and registered to do business in Cyprus. 5. Badoo Software has no headquarters and no places of business in the United States. 6. Badoo Software has no ownership relationship with Bumble Trading, Inc. or Bumble Holding, Limited. 7. Badoo Software owns no property in Texas. 8. Badoo Software leases no property in Texas. Badoo Software has no offices in Texas. Badoo Software has no bank accounts in Texas. Badoo Software has no employees in Texas. Badoo Software does not have contractors in Texas. 13. Badoo Software is not registered to do business in Texas. 14. Badoo Software does not pay any taxes either to the State of Texas or to cities in Texas. 15. Badoo Software does not have an agent for service of process in Texas. 16. Badoo Software does not operate, market, or manage distribution of the Bumble app. 17. Badoo Software receives its revenue from Badoo Trading Ltd. 18. Badoo Software never authorized a representative to travel to Texas to represent Badoo Software 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 Software to defend this action in Texas. All of Badoo Software's potential witnesses are located outside of the United States. Additionally, none of Badoo Software'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 07 2019. in Valletta Luke Frendo 211668845