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 TARA EAVES IN SUPPORT OF MICROSOFT CORPORATION’S 

MOTION TO TRANSFER VENUE TO AUSTIN DIVISION

Case 6:20-cv-00465-ADA Document 29-1 Filed 10/02/20 Page 1 of 5
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I, Tara Eaves, declare as follows:

1. I am employed as a Human Resources Data Analyst Group Manager 

at Microsoft Corporation (“Microsoft”). I am based in Redmond, Washington,

where I manage a team of reporting analysts within Human Resources. 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. 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. 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. I am further informed and understand that there are a total of twelve 

patent infringement cases filed by Plaintiff in the Waco Division and that these 

cases accuse various Microsoft products of infringing certain United States patents. 

I understand the accused products include certain aspects of Microsoft’s Azure 

Cloud System, Xbox, Skype, Teams, HoloLens, and Windows Server. 

5. Microsoft is a Washington corporation with its worldwide 

headquarters at One Microsoft Way in Redmond, Washington.

6. Microsoft does not maintain any office space or business location in 

the Waco Division of the Western District of Texas. 

Case 6:20-cv-00465-ADA Document 29-1 Filed 10/02/20 Page 2 of 5
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7. There are 188 Microsoft personnel that work at Microsoft facilities in 

Austin, Texas.

8. Microsoft’s engineering, sales, and financial documents are primarily 

located in Redmond, Washington. Microsoft is not aware of any documents

related to the accused products located in the Waco Division. Microsoft has no 

data centers in the Waco Division. There are 20 employees in Marketing groups in 

the state of Texas, with none who work in Waco and 11 who work in Austin.

9. I reviewed Microsoft’s Human Resources records for the Skype 

Infrastructure organization. Based on my review, I found no personnel that are 

part of the Skype Infrastructure organization in Austin. There are no Skype or 

Teams personnel in the Waco Division. Based on my review of Human Resources 

records, there is one employee in the Marketing group for Skype or Teams in the 

state of Texas, who is located in Dallas. There are none in Austin. Strategic 

decision making regarding Skype and Teams happens in the state of Washington. 

10. I reviewed Microsoft’s Human Resources records for the COSinE 

organization. Based on my review, there are three personnel in Austin who are 

part of the COSinE organization. There are no Windows Server personnel in the 

Waco Division. Based on my review of Human Resources records, there are no 

employees in the Marketing group for Windows Server in the state of Texas. 

Strategic decision making regarding Windows Server happens in the state of 

Washington.

11. I reviewed Microsoft’s Human Resources records for the Mixed 

Reality organization. Based on my review, there are two personnel that are part of 

the Mixed Reality organization in Austin. There are no HoloLens personnel in the 

Waco Division. Based on my review of Human Resources records, there are no 

Case 6:20-cv-00465-ADA Document 29-1 Filed 10/02/20 Page 3 of 5
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employees in the Marketing group for HoloLens in the state of Texas. Strategic 

decision making regarding HoloLens happens in the state of Washington. 

12. I reviewed Microsoft’s Human Resources records for Azure Core. In 

reviewing Microsoft’s Human Resources records, the total number of employees 

under the Azure Core organization in Austin is 20, whereas 7,801 are located in 

Redmond, Washington. There are no Azure personnel in the Waco Division. 

Based on my review of Human Resources records, there are no employees in the 

Marketing group for Azure in the state of Texas. Strategic decision making 

regarding Azure happens in the state of Washington. 

13. I reviewed Microsoft’s Human Resources records for Xbox. Based on 

my review, there are no personnel that are part of Xbox in Austin. There are no 

Xbox personnel in the Waco Division. Based on my review of Human Resources 

records, there are no employees in the Marketing group for Xbox in the state of 

Texas. Strategic decision making regarding Xbox happens in the state of 

Washington. 

14. Based on my review of the Human Resources records for all Texas

Microsoft employees, there are two Microsoft personnel with home offices in the 

Waco division. One is located in Waco, and is in the digital sales, sales academy, 

and learning and development group. The second is a customer success account 

manager in sales and marketing. Neither is part of the organizations mentioned 

above. 

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