Free Declaration - District Court of Delaware - Delaware

Case 1 :06-cv-00032-JJF Document 277 Filed 01/11/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
POR THE DISTRICT OP DELAWARE
RR. DONNELLEY & SONS COMPANY, )
)
Plaintiff, )
)
v. ) Case No. 06-cv—032—]IF
)
CREO, INC., NEXPRESS SOLUTIONS, )
INC., KODAK VERSAMARK, INC., )
EASTMAN KODAK COMPANY, and )
KODAK GRAPHIC COMMUNICATIONS )
COMPANY, )
)
Defendants. )
)
EASTMAN KODAK COMPANY, )
-
Counterclaiin—PlaintiftQ )
)
v. )
)
R.R. DONNELLEY & SONS COMPANY, )
)
Counterclaim-Defendant. )
- )
DECLARATION OF COLEMAN KANE IN SUPPORT OF THIRD PARTY PRINTABLE
TECHNOLOGIES, INC.’S RESPONSE TO PLAINTIFIPS MOTION TO COMPEL ITS
RULE 30gB)g6) DEPOSITION
I, Coleman F. Kane, declare as follows:
1. I am the Chief Executive Officer of Printable Technologies Inc. I have held that
position since 2000. I have personal knowledge ofthe below facts and if called as a witness, I
could competently testify to these facts.
2. Printable Technologies Inc.’s principal offices are located in San Diego County,
California at 201 Lomas Santa Pe Drive, Suite 270, Solana Beach, CA 92075.
3. Printable Technologies Inc. does not have an office in Delaware and does not
l
siizis misc

Case 1:06—cv—00032-JJF Document 277 Filed 01/11/2008 Page 2 of 2
have any officers, directors or employees in the Delaware. U
4. Printable Technologies Inc. does not employ or otherwise have available a person
to designate in response to RR. Donnelley & Sons Company’s notice of deposition that resides
or works in Delaware or within one hundred miles of Delaware.
5. lt would be very burdensome and expensive for Printable Technologies lnc. to
send designees and counsel to Delaware for deposition by R..R.. Donnelley & Sons Company in
this matter.
6. Printable Technologies lnc. is a Delaware corporation with a registered agent of
service in Delaware.
l declare under penalty of perjury under the laws ofthe United States of America that the
foregoing is true and correct. Executed on January 2, 2008, in San Diego, California.
Coleman P. Kane
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