Exhibit 5

Case 2:24-cv-00093-JRG Document 82-5 Filed 09/20/24 Page 1 of 8 PageID #: 3926
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UNITED STATES DISTRICT COURT

FOR THE WESTERN DISTRICT OF TEXAS

MIDLAND/ODESSA DIVISION

VIRTAMOVE, CORP.,

Plaintiff,

v.

GOOGLE LLC,

Defendant.

Case No. 7:24-cv-00033-DC-DTG

JURY TRIAL DEMANDED

PLAINTIFF’S SUPPLEMENTAL OBJECTIONS AND RESPONSES TO 

DEFENDANT’S FIRST SET OF VENUE INTERROGATORIES (NOS. 1-4) AND 

RESPONSES TO DEFENDANT’S SECOND SET OF VENUE INTERROGATORIES 

(NO. 5)

Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Plaintiff VirtaMove 

Corp. (“VirtaMove”) corrects and supplements its responses to Defendant Google LLC’s

(“Defendant” or “Google”) First Set of Venue Requests for Interrogatories on as follows:

VirtaMove’s responses are based on information known and available to it at the time of 

these responses. VirtaMove’s investigation in this matter is ongoing. Further, because all 

information and documents that are possibly within the scope of the Interrogatories may have yet 

to be located and/or identified, the development of VirtaMove’s contentions with respect to its 

claims and defenses is ongoing. VirtaMove reserves the right to assert additional objections to the 

Interrogatories and to modify and supplement its responses pursuant to Rule 26(e) of the Federal 

Rules of Civil Procedure.

VirtaMove’s responses to these Interrogatories are not to be construed as admissions that 

any of the requested information exists or that any contention or assumption contained in the 

Interrogatories, whether implicit or explicit, is correct.

Case 2:24-cv-00093-JRG Document 82-5 Filed 09/20/24 Page 2 of 8 PageID #: 3927
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VM_GOOGLE_0001128; VM_GOOGLE_0001181; VM_GOOGLE_0001182-

VM_GOOGLE_0001185.

REQUEST NO. 2:

Identify the following Persons, the city and state in which they reside (current or last

known), their title, role, responsibilities, and location of workplace, and a description of their

knowledge as it relates to this Action:

(a) All named inventors on the Asserted Patents and/or Related Patents;

(b) All Persons with knowledge of the prosecution of the Asserted Patents and/or Related 

Patents;

(c) All Persons with knowledge about the licensing of the Asserted Patents and/or Related 

Patents;

(d) All Persons that You consider to be a likely or anticipated witness in this Action 

(whether a VirtaMove employee, a Third Party, or otherwise); and

(e) All Persons with a financial interest in the outcome of this Action, and the type and 

amount of their financial interest, including but not limited to, any agreements reflecting such 

financial interest.

RESPONSE TO REQUEST NO. 2:

Incorporating the General Objections, above, VirtaMove additionally objects to this 

interrogatory as overbroad, unduly burdensome, irrelevant, and not proportional to the needs of 

the Google’s motion. VirtaMove further objects to this Interrogatory as compound and containing 

multiple subparts. VirtaMove further objects to this interrogatory to the extent it seeks information 

in the possession of third parties and not VirtaMove. VirtaMove further objects to the extent this 

interrogatory seeks information protected from disclosure by the attorney-client privilege, work 

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product doctrine, common interest doctrine and/or any other applicable privilege. VirtaMove 

further objects that this interrogatory seeks information known to third parties outside of 

VirtaMove’s possession, custody, or control. VirtaMove further objects that this request is 

overbroad and unduly burdensome because it seeks “All” Persons. VirtaMove objects that this 

request seeks attorney-client privileged information about its arrangement with counsel. 

VirtaMove objects that discovery into litigation funding, if it exists, is not discoverable.

Subject to and without waiving the foregoing objections, VirtaMove responds that the 

following individuals may have relevant knowledge to topics (a)-(e).

Name Last Known 

Location

Title/Relevance

Bill Cullen Massachusetts Former CTO 

Donna Grare New York Former VP of Product Development

Giovanni Boschi Massachusetts Former CTO

Mohammed Ahmed-Mushin Ontario, Canada Former Software Developer

Robert Wang Ontario, Canada Former Software Developer

Mark Woodward Ontario, Canada Former VP Development

Donn Rochette Iowa Named inventor

Paul O’Leary Ontario, Canada Named inventor 

Dean Huffman Ontario, Canada Named inventor

Craig MacDonald Washington Former Senior Developer

Greg O’Connor East Coast Former President & CEO

Chuck Colford Ontario, Canada Former CEO

Ron Warburton Ontario, Canada Former Interim CEO and Board Member

David Roth Texas Former CEO

Nigel Stokes Ontario, Canada VirtaMove CEO

Cedric Burgins Ontario, Canada VirtaMove Director of Technology

Emanuel Sousa Ontario, Canada VirtaMove Senior Technical Specialist 

Susan Cameron Ontario, Canada VirtaMove Office Manager

Steven Antonie Ontario, Canada VirtaMove IT Manager

Rich Gold Massachusetts Director of Sales

Adine Deford Florida Vice President of Marketing

Ernesto Benedito Texas Software Development Team Lead

Greg Feldman Las Vegas, 

Nevada

Customer Advocate

Jose Roy New Hampshire Director of Business Development

Tracy Riser Washington Director of Business Development

Robert DelSignore Massachusetts Director Field Engineering

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Ronnie Taylor San Luis, CA Software Developer

FIRST SUPPLEMENTAL RESPONSE TO REQUEST NO. 2 (SEPTEMBER 20, 2024):

Name Last Known 

Location

Title/Relevance

Bill Cullen Cambridge, 

Massachusetts

Former1 CTO; knowledge of past 

technology 

Donna Grare New York City 

Metropolitan Area, 

New York

Former VP of product development; 

knowledge of past product development, 

relevant to pre-suit marking dispute

Giovanni Boschi Pepperell, 

Massachusetts

Former CTO; knowledge of past technical 

information of product, relevant to presuit marking dispute

Mohammed Ahmed-Mushin Ottawa, 

Ontario, Canada

Former Software Developer; knowledge 

of past software operation of product, 

relevant to pre-suit marking dispute

Robert Wang Ottawa, Ontario, 

Canada

Former Software Developer; knowledge 

of past software operation of product, 

relevant to pre-suit marking dispute

Mark Woodward Kingston, Ontario, 

Canada

Former VP of Product Engineering; 

knowledge of past engineering of product, 

relevant to pre-suit marking dispute

Donn Rochette Dayton 

Metropolitan Area, 

Ohio

Named inventor

Paul O’Leary Ottawa, Ontario, 

Canada

Named inventor 

Dean Huffman Ottawa, Ontario, 

Canada

Named inventor

Craig MacDonald Redmond, 

Washington

Former Senior Developer, knowledge of 

past development of product, related to 

pre-suit marking dispute

Greg O’Connor Primarily 

Chilmark, 

Massachusetts 

with vacation 

home near Lake 

Tahoe, CA

Former President, general knowledge of 

company history.

Chuck Colford Ottawa, Ontario, 

Canada

Former CEO, general knowledge of 

company history.

Ron Warburton Ottawa, Ontario, 

Canada

Former Member of Board, general 

knowledge of company history.

1 Former may refer to work at VirtaMove or its predecessors AppZero and Trigence.

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David Roth Dallas, Texas Former CEO, general knowledge of 

company history.

Nigel Stokes Toronto, Ontario, 

Canada

VirtaMove CEO, general knowledge of 

information related to VirtaMove

Cedric Burgins Ottawa, Ontario, 

Canada

VirtaMove Director of Technology, 

potential technical related to the operation 

of VirtaMove product, relevant to pre-suit 

marking dispute

Emanuel Sousa Arnprior, Ontario, 

Canada

VirtaMove Senior Technical Specialist, 

potential technical related to the operation 

of VirtaMove product, relevant to pre-suit 

marking dispute 

Susan Cameron Ottawa, Ontario, 

Canada

VirtaMove manager, document custodian, 

topics related to business records

Steven Antoine Ottawa, Ontario, 

Canada

VirtaMove IT Manager, topics related to 

business records.

Samantha Clarke Freemont, CA Former sales

Ernesto Benedito Dallas/Fort Worth 

Metro, Texas

Former Software Development Team 

Lead

Greg Feldman Henderson, 

Nevada

Former Customer Advocate

Rich Gold Brookline, 

Massachusetts

Former Director of Sales

Adine Deford Naples, Florida Former Vice President of Marketing

Jose Roy Greater Boston, 

Massachusetts

Former Director of Business 

Development

Tracy Riser Greater Seattle 

Area, Washington

Former Director of Business 

Development

Robert DelSignore Westwood, 

Massachusetts

Former Director Field Engineering

Ronnie Taylor Pismo Beach, 

California

Former Software Developer

Teitelbaum & MacLean Ottawa, Ontario, 

Canada

Knowledge of the Asserted or Related 

Patents

MBM Intellectual Property Ottawa, Ontario, 

Canada

Knowledge of the Asserted or Related 

Patents

Alex Topitsch Ajax, Ontario, 

Canada

Former VP Sales

VirtaMove further incorporates under Rule 33(d) Dkt. 78-30 from the IBM case 2:24-cv-00093 

(E.D. Tex.), but VirtaMove contends that none of the Board members aside from Nigel Stokes are 

likely to attend trial. VirtaMove further incorporates under Rule 33(d) the asserted patents and 

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their file history that identify any other firms with knowledge of the Asserted Patents and Related 

Patents. VirtaMove further incorporates under Rule 33(d) the venue declarations of Colford, Estes, 

Huffman, O’Leary, Woodward, and O’Connor. VirtaMove further incorporates under Rule 33(d) 

the testimony and declaration of Vasetsky. According to TravelMath.com, the straight-line flight 

distance from Israel is shorter to Midland, Texas than to San Francisco, California. 

REQUEST NO. 3:

Identify and describe all facts pertaining to the alleged connection between this Action 

and the Western District of Texas and/or the Northern District of California, if any, and all facts 

upon which You intend to rely in Your Response to Defendant’s Motion to Transfer Venue to 

the Northern District of California Under 28 U.S.C. 1404 (Dkts. 44-1, 48) or any re-filed motion 

to transfer venue, including any facts pertaining to whether it is easier for any individual You 

identified in response to Interrogatory No. 2 to travel to the Midland/Odessa Division compared 

to the Northern District of California.

RESPONSE TO REQUEST NO. 3 (CORRECTED SEPT. 20, 2024):

VirtaMove incorporates its General Objections, above. VirtaMove additionally objects to 

this interrogatory as overbroad, unduly burdensome, irrelevant, and not proportional to the needs 

of the case. VirtaMove further objects to this Interrogatory to the extent it is a premature contention 

interrogatory that purports to require VirtaMove to identify all facts or evidence with respect to a 

particular topic or issue in advance of the deadline set forth in the Scheduling Order. VirtaMove

further objects to this Interrogatory as compound and containing multiple subparts. VirtaMove

further objects to the extent this interrogatory seeks information protected from disclosure by the 

attorney-client privilege, work product doctrine, common interest doctrine and/or any other 

applicable privilege.

Case 2:24-cv-00093-JRG Document 82-5 Filed 09/20/24 Page 7 of 8 PageID #: 3932
CERTIFICATE OF SERVICE

The undersigned certifies that on September 20, 2024 all counsel of record who are deemed 

to have consented to electronic service are being served with a copy of this document via electronic 

mail.

/s/ Reza Mirzaie

Reza Mirzaie

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