IN THE UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

WACO DIVISION

WSOU INVESTMENTS, LLC D/B/A 

BRAZOS LICENSING AND

DEVELOPMENT,

Plaintiff,

v. 

MICROSOFT CORPORATION,

Defendant.

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CIVIL ACTION 6:20-cv-00454-ADA

CIVIL ACTION 6:20-cv-00455-ADA

CIVIL ACTION 6:20-cv-00456-ADA

CIVIL ACTION 6:20-cv-00457-ADA

CIVIL ACTION 6:20-cv-00458-ADA

CIVIL ACTION 6:20-cv-00459-ADA

CIVIL ACTION 6:20-cv-00460-ADA

CIVIL ACTION 6:20-cv-00461-ADA

CIVIL ACTION 6:20-cv-00462-ADA

CIVIL ACTION 6:20-cv-00463-ADA

CIVIL ACTION 6:20-cv-00464-ADA

CIVIL ACTION 6:20-cv-00465-ADA

DECLARATION OF SANDY PARK IN SUPPORT OF MICROSOFT 

CORPORATION’S MOTION TO TRANSFER VENUE TO AUSTIN DIVISION

Case 6:20-cv-00465-ADA Document 29-2 Filed 10/02/20 Page 1 of 4
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I, Sandy Park, declare as follows:

1. I am employed as a Director, Western United States in the Real Estate 

& Facilities group at Microsoft Corporation (“Microsoft”) and in that role I 

oversee real estate planning, leasing, and day to day operations of Microsoft 

facilities on the West Coast and in Texas. I have been employed by Microsoft 

since 1997.

2. I submit this declaration in support of Microsoft’s Motion for IntraDistrict Transfer to the Austin Division of the Western District of Texas in the 

above-captioned litigation. Unless otherwise indicated, the statements in this 

declaration are based upon my personal knowledge and/or based on corporate 

records maintained by Microsoft in the ordinary course of business.

3. I have been informed and understand that Plaintiff WSOU 

Investments LLC (“Plaintiff”) has filed the above-captioned patent infringement 

lawsuit against Microsoft in the Waco Division of the Western District of Texas. I 

am further informed and understand that the Waco Division of the Western District 

includes the following counties: Bell, Bosque, Coryell, Falls, Freestone, Hamilton, 

Hill, Leon, Limestone, McLennan, Milam, Robertson, and Somervell.

4. Microsoft’s main Austin, Texas location is at 10900 Stonelake 

Boulevard, Suite 225, Austin, TX, 78759 (“the 10900 facility”). The 10900 

facility is approximately 20,000 square feet and comprises one floor of a multitenant building. Microsoft has been leasing space at the 10900 facility since 2009.

The 10900 facility is primarily a regional sales office. In addition to sales 

personnel, the 10900 facility also hosts members of other groups whose primary 

function is to support Regional Sales efforts and any other employees or functions 

in the area. Personnel in those other groups include Enterprise Sales & Support;

Case 6:20-cv-00465-ADA Document 29-2 Filed 10/02/20 Page 2 of 4
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Search Advertising Sales; Support Engineers; Corporate, External, and Legal 

Affairs; and Finance personnel. 1 

5. The 10900 facility is secured and is accessible only to those with a 

Microsoft employee badge or authorized visitors. Access to the 10900 facility is 

available to visiting Microsoft employees upon request and has previously and 

regularly been used to host employees in need of temporary work space when 

visiting Austin. Visiting Microsoft employees may request access to the 10900 

facility through an internal Microsoft security webpage. The 10900 facility 

includes shared space to host outside visitors and separately secured Microsoft 

employee-only space. 

6. Under non-COVID-19 conditions, approximately 50 visitors may be 

hosted at the 10900 facility at a given time. Visiting Microsoft employees may 

reserve a “hot desk” style workstation and also make use of the facilities’ phone 

and focus rooms. Visiting employees may also use conference rooms and 

audiovisual systems. 

7. Visiting employees to the 10900 facility have full access to 

Microsoft’s corporate high speed internet connection and Microsoft’s private

Corporate Network, which was installed into the facility. Visiting employees can 

use the office’s networked printers and scanners. In-person IT support can be 

dispatched to the office if online support does not solve the visiting employee’s IT 

issue. Facilities, reception, and other support staff are available to assist visiting 

employees during business hours. 

 

1 Due to COVID-19, the presence of employees on-site is currently more limited 

and restricted. My expectation is that after COVID-19 restrictions are lifted, the 

office will continue to be used as it was normally used prior to the pandemic. 

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