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`Exhibit 3
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`
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`Case 1:19-cv-07529-DLC Document 18-3 Filed 10/03/19 Page 2 of 3
`Case 1:19-cv-07529-DLC Document 18-3 Filed 10/03/19 Page 2 of 3
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`IN THE UNITED STATES DISTRICT COURT
`
`FOR THE SOUTHERN DISTRICT OF NEW YORK
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`Bot M8 LLC,
`
`Plaintiff,
`
`v.
`
`Civil Action No. l:l9-cv-07529-DLC
`
`SONY CORPORATION OF AMERICA, SONY
`CORPORATION, and SONY INTERACTIVE
`
`ENTERTAINMENT AMERICA LLC,
`
`Defendants.
`
`DECLARATION OF GEORGE CACIOPPO
`
`1, George Cacioppo, declare as follows:
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`1.
`
`I am Senior Vice President of Network Platform & Services Engineering at Sony
`
`Interactive Entertainment LLC (“SIE LLC”).
`
`I am responsible for network platform and services
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`engineering initiatives at SIE LLC, and I focus on the planning, coordinating, directing, and
`
`designing of engineering activities of the engineering organization in support of the
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`PlayStation® Network Platform.
`
`I have been employed by SIE LLC or its predecessors-in-
`
`interest since 2013.
`
`I am familiar with the facts set forth herein and could testify competently
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`thereto.
`
`2.
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`I submit this Declaration in support of SIE LLC’s motion to transfer this case due
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`to improper venue.
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`3.
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`The facts set forth in this Declaration were true as of August 12, 2019 and remain
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`true at present.
`
`
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`Case 1:19-cv-07529-DLC Document 18-3 Filed 10/03/19 Page 3 of 3
`Case 1:19-cv-07529-DLC Document 18-3 Filed 10/03/19 Page 3 of 3
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`4.
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`I have been informed that the plaintiff in this case has made the following
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`assertion in its Complaint:
`
`Sony operates the PlayStation Network on PlayStation game servers, powerful
`computers used to store files including user account information, social network
`information, gaming programs, and gaming results. Sony’s PlayStation game
`servers are located throughout the United States, including in Bronx, New York.
`
`As I explain below, this assertion requires several corrections.
`
`5.
`
`The PlayStation® Network handles user account creation, maintenance, and sign
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`in features, game play and social community services, and online store purchases on third-party
`
`servers provided via a contractual arrangement with a third-party cloud services provider, not on
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`the servers of SIB LLC. A small number of backend supporting services for the PlayStation®
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`Network, primarily related to security and business operations and reporting, are provided via
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`servers of SIE LLC, but none of these servers are located in the State of New York.
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`6.
`
`The PlayStation® Network also handles storage and execution of video game
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`programs for PlayStation® Now via servers of SIE LLC. These servers are located at several
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`facilities in the United States, including in Milpitas, California. None of these servers are located
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`in the State of New York.
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`I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge.
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`Executed on Octoberuzf, 2019
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`
`
`
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