EXHIBIT 2

Case 2:23-cv-00617-RWS-RSP Document 38-2 Filed 04/25/24 Page 1 of 4 PageID #: 458
DECLARATION OF JESSICA VITTORIO

ON BEHALF OF CAPTANA GMBH PAGE 1

IN THE UNITED STATES DISTRICT COURT

EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

HANSHOW TECHNOLOGY CO., 

LTD. AND SHANGHAI HANSHI 

INFORMATION TECHNOLOGY

CO., LTD

Plaintiffs,

v. 

SES-IMAGOTAG SA, SESIMAGOTAG GMBH AND 

CAPTANA GMBH

Defendants. 

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Case No. 2:23-cv-00617-RWS-RSP

DECLARATION OF JESSICA VITTORIO

1. My name is Jessica Vittorio. I am over the age of 21 years old, and I have never 

been convicted of a felony. I am of sound mind, and I am otherwise competent to make this 

Declaration. For the limited purpose of stating facts in support of Captana GmbH’s Motion to 

Dismiss for Lack of Personal Jurisdiction, I have been designated as the corporate representative 

of Captana GmbH. The facts stated in this Declaration are within my personal knowledge and are 

true and correct. 

2. I oversee all legal aspects of commercial activities and operations for VusionGroup 

SA in the United States. Because of this, I have working knowledge of how sales are effectuated 

amongst the defendants and other affiliates of VusionGroup SA, including the structure of those 

companies, and the manufacturing, customs, and other logistics involved in U.S. sales of the 

accused products in this case.

Case 2:23-cv-00617-RWS-RSP Document 38-2 Filed 04/25/24 Page 2 of 4 PageID #: 459
DECLARATION OF JESSICA VITTORIO

ON BEHALF OF CAPTANA GMBH PAGE 2

3. VusionGroup SA (f/k/a SES-imagotag SA) is a French corporation and the parent 

company of Defendant Captana GmbH. 

4. VusionGroup SA is a technology developer that sells its products in Europe. One 

such device is the CaptanaTM sensor and camera system.

5. Captana GmbH ("Captana") is corporation organized and existing under the laws 

of Germany. 

6. Although it is a wholly owned subsidiary of VusionGroup SA, Captana GmbH is a 

legally distinct entity from Defendants VusionGroup SA (f/k/a SES-Imagotag SA) and 

VusionGroup GmbH.

7. Captana GmbH began as a technology startup known as Findbox.

8. SES-Imagotag SA acquired a controlling interest in Captana GmbH in 2017.

9. Captana GmbH has been an independent, operational company and brand before 

and after SES-imagotag SA’s acquisition. It develops its own technologies and has maintained

largely uninterrupted leadership, with Michael Unmussig serving as its CEO since its founding.

10. Captana GmbH develops technology that is used in the CaptanaTM products. 

11. Captana GmbH does not maintain a place of business or employees in the United 

States or the State of Texas.

12. Captana GmbH does not sell, advertise, import, or make the CaptanaTM devices in 

Texas or the United States. 

13. My name is Jessica Vittorio. My date of birth is February 6, 1991. I declare under 

penalty of perjury under the laws of the United States of America that the foregoing is true and 

correct.

Case 2:23-cv-00617-RWS-RSP Document 38-2 Filed 04/25/24 Page 3 of 4 PageID #: 460
DECLARATION OF JESSICA VITTORIO

ON BEHALF OF CAPTANA GMBH PAGE 3

Executed on the ___ day of ________________ 2024. 

Jessica Vittorio

Case 2:23-cv-00617-RWS-RSP Document 38-2 Filed 04/25/24 Page 4 of 4 PageID #: 461