Match Group, LLC v. Bumble Trading Inc.

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

Affidavit Declaration of Vladimir Kornilovski iso Badoo Technology Limiteds Moti

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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 TECHNOLOGIES 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 Technologies Limited's ("Badoo Technologies") Motion to Dismiss. 3. I am a director of Badoo Technologies. 4. Badoo Technologies is a company incorporated and registered to do business in Cyprus. 5. Badoo Technologies has no headquarters and no places of business in the United States. 6. Badoo Technologies has no ownership interest in Bumble Holding Ltd. and Bumble Trading Inc. 7. Badoo Technologies owns no property in Texas. 8. Badoo Technologies leases no property in Texas. Badoo Technologies has no offices in Texas. Badoo Technologies has no bank accounts in Texas. Badoo Technologies has no employees in Texas. Badoo Technologies does not have contractors in Texas. 13. Badoo Technologies is not registered to do business in Texas. 14. Badoo Technologies does not pay any taxes either to the State of Texas or to cities in Texas. 15. Badoo Technologies does not have an agent for service of process in Texas. 16. Badoo Technologies does not operate, market, or manage distribution of the Bumble app. 17. Badoo Technologies does not receive any revenue from the Bumble app. 18. Badoo Technologies does not receive any revenue from the Bumble app. 19. Badoo Technologies never authorized a representative to travel to Texas to represent Badoo Technologies in discussions regarding a potential acquisition of Bumble Trading, Inc. or Bumble Holding, Ltd. by Match Group, LLC. 20. It would be extremely burdensome for Badoo Technologies to defend this action in Texas. All of Badoo Technologies' potential witnesses are located outside of the United States. Additionally, none of Badoo Technologies' 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 Vladimir Komit Vladimir Kornilovski