Match Group, LLC v. Bumble Trading Inc.

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

Affidavit Declaration of Vladimir Kornilovski iso Badoo Limiteds Motion to Dismi

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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 VLADIMIR KORNILOVSKI IN SUPPORT OF DEFENDANT BADOO LIMITED'S MOTION TO DISMISS PLAINTIFF MATCH GROUP, LLC'S FOURTH AMENDED COMPLAINT I, Vladimir Kornilovski 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 Limited's Motion to Dismiss. 3. I am a director of Badoo Limited. Badoo Limited is a company incorporated and registered to do business in the United Kingdom. 4. 5. Badoo Limited has no headquarters and no places of business in the United States. Badoo Limited has no ownership relationship to Bumble Trading, Inc. or Bumble Holding Limited. 6. Badoo Limited owns no property in Texas. Badoo Limited leases no property in Texas. 8. Badoo Limited has no offices in Texas. 9. Badoo Limited has no bank accounts in Texas. Badoo Limited has no employees in Texas. Badoo Limited does not have contractors in Texas. 12. Badoo Limited is not registered to do business in Texas. 13. Badoo Limited does not pay any taxes either to the State of Texas or to cities in Texas. 14. Badoo Limited does not have an agent for service of process in Texas. 15. Badoo Limited does not operate, market, or manage distribution of the Bumble app. 16. Badoo Limited does not receive any revenue from the Bumble app. 17. It would be extremely burdensome for Badoo Limited to defend this action in Texas. All of Badoo Limited's potential witnesses are located outside of the United States. Additionally, none of Badoo Limited'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 8, 2019, in_LONDON UK Vladimir Kornilovski 211667729