Exhibit 8

Case 2:24-cv-00093-JRG Document 102-8 Filed 11/05/24 Page 1 of 8 PageID #: 5053
IN THE UNITED STATES DISTRICT COURT

FOR THE EASTERN DISTRICT OF TEXAS

MARSHALL DIVISION

VIRTAMOVE, CORP.,

Plaint

v.

HEWLETT PACKARD ENTERPRISE

COMPANY,

Defendant.

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Case No. 2:24-cv-00093-JRG

(Lead Case)

JURY TRIAL DEMANDED

VIRTAMOVE, CORP.,

Plaint

v.

INTERNATIONAL BUSINESS MACHINES

CORP.,

Defendant.

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Case No. 2:24-CV-00064-JRG

(Member Case)

JURY TRIAL DEMANDED

DECLARATION OF DEAN HUFFMAN

IN SUPPORT OF PLAINTIFF VIRTAMOVE, CORP.’S OPPOSITION TO

MOTION TO TRANSFER VENUE

Case 2:24-cv-00093-JRG Document 102-8 Filed 11/05/24 Page 2 of 8 PageID #: 5054
I, Dean Huffman, declare and state as follows:

1. I have personal knowledge of the facts set forth herein, and if called upon to testify,

could and would testify competently thereto.

2. I currently work as a software developer at Cisco Systems.

3. I currently reside in Kanata, Ontario, Canada.

4. I am listed as an inventor on U.S. Patent 7,519,814 and U.S. Patent 7,784,058.

5. I am willing and expect to travel to Texas to testify in the above-captioned cases. I

do not personally find this inconvenient. I do find cross-continental travel to the NDCA to be

inconvenient.

6. I am willing and expect to travel to Texas in relation to Plaintiffs co-pending cases

VirtaMove, Corp. v. Google LLC, No. 7:24-cv-33 (W.D. Tex); VirtaMove, Corp. v. International

Business Machines Corp., No. 2:24-cv-64 (E.D. Tex); and VirtaMove, Corp. v. Hewlett Packard

Enterprise Company, No. 2:24-cv-96 (E.D. Tex). I expect to regularly travel to Texas to prepare

for, attend hearings in, and testify in these cases, so I would not find travel for any one specific

case in Texas to be inconvenient if I will be in Texas for other cases anyway. I have no specific

plans to travel to the Northern District of California.

7. I would prefer to travel to Marshall, Texas for trial instead of to the Northern

District of California because I believe it will be both less expensive and closer.

8. For expenses, I have estimated my per-diem rates using the GSA website, and San

Francisco looks to be more than two or three times as expensive, depending on the month. Below

are true and correct screenshots of the GSA estimated rates for Marshall, Texas and San

Francisco, CA from:

https://www.gsa.gov/travel/plan-book/per-diem-rates/per-diem-rates-results?action=perdi

ems_report&fiscal_year=2024&state=CA&city=San+Francisco, and

https://www.gsa.gov/travel/plan-book/per-diem-rates/per-diem-rates-results?action=perdi

Case 2:24-cv-00093-JRG Document 102-8 Filed 11/05/24 Page 3 of 8 PageID #: 5055
ems_report&fiscal_year=2024&state=TX&city=Marshall.

9. If I needed to travel a whole week for trial plus several days of preparation, then I

estimate the resulting cost difference to be substantially less expensive in Marshall, Texas.

10. I have used the website www.travelmath.com to estimate my straight-line flying

times between Kanata, ON, Canada to both Marshall, Texas and to San Francisco, California.

The following are true and correct excerpts showing that the estimated travel times and travel

Case 2:24-cv-00093-JRG Document 102-8 Filed 11/05/24 Page 4 of 8 PageID #: 5056
distances are more convenient for Marshall, Texas (3 hours, 9 minutes to travel 1,323 miles) as

compared to San Francisco (4 hours, 52 minutes to travel 2,435 miles).

. . .

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Case 2:24-cv-00093-JRG Document 102-8 Filed 11/05/24 Page 5 of 8 PageID #: 5057
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Case 2:24-cv-00093-JRG Document 102-8 Filed 11/05/24 Page 6 of 8 PageID #: 5058
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Case 2:24-cv-00093-JRG Document 102-8 Filed 11/05/24 Page 7 of 8 PageID #: 5059
11. Based on these estimates, I believe that my travel to Marshall, Texas will be much

more convenient than travel to San Francisco, California because my travel will be less

expensive, faster, and closer. For these reasons, I am unwilling to travel to San Francisco,

California for trial.

12. I declare under penalty of perjury pursuant to the laws of the United States that the

foregoing is true and correct.

Executed on September 10, 2024 at Kanata, Ontario, Canada.

_____________________

Dean Huffman

Case 2:24-cv-00093-JRG Document 102-8 Filed 11/05/24 Page 8 of 8 PageID #: 5060