Free Affidavit - District Court of Delaware - Delaware

Case 1 :07-cv-00753-JJF Document 46 Filed 01/11/2008 Page 1 of 2
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF DELAWARE
Case N0. 07-753
ROCHE DIAGNOSTICS OPERATIONS, INC., )
and CORANGE INTERNATIONAL LIMITED, )
Plaintiffs, )
v. ) H Q RD
ABBOTT DIABETES CARE, INCORPORATED, ) AFFIDAVIT OF RIO
_ ADMANI IN SUPPORT OF
ABBOTT DIABETES CARE SALES ) DIAGNOSTIC DEVICES
OORRORATION ) INC ·s MoT1oN TO msivuss
BAYER HEALTHCARE, LLC, ) °
DIAGNOSTICS DEVICES, INC., )
LIFESCAN, INCORPORATED, )
NOVA BIOMEDICAL CORPORATION, and )
SANVITA INCORPORATED, )
Defendants. )
Richard Admani, being duly swom, deposes and says:
l. I am over the age of eighteen and am under no disability which would render me
incompetent to make this affidavit. I have personal knowledge of all the matters stated in this
affidavit, and all statements made are true and correct.
2. I am the Chief Operating Officer for Diagnostic Devices, Inc ("DDI").
3. DDI is a North Carolina corporation with its principal place of business in
Charlotte, North Carolina. DDI sells diabetic testing meters and strips under the trade name
Prodigy® for distribution to patients suffering from diabetes.
4. DDI has never employed any officers, employees, or agents in Delaware except
for an attorney in connection with its defense of the claims related to this litigation.
5. DDI has never sold any products to any distributor or individual in Delaware.
6. DDI has never shipped any products to Delaware.
7. DDI does not service any warranties for products in Delaware.
8. DDI has never targeted any advertising to Delaware.
9. DDI has never been licensed to do business in Delaware.

CLT 109786svi

Case 1:07-cv-00753-JJF Document 46 Filed 01/1 1/2008 Page 2 of 2
10. DDI has no plan to specifically target Delaware customers.
1 1. DDI has never had an agent for service of process in Delaware.
12. DDI has not entered into any contracts in Delaware.
13. DDI has never leased or owned property in Delaware.
14. DDI has never maintained an office, facility, or telephone listing in Delaware.
15. DDI has never had a bank account in Delaware.
16. DDI executives have not traveled to Delaware in the last ten years for any
business pI1I'pOS€.
17. DDI maintains a website at www.pr0digymeter.com available to anyone with
access to the world wide web. The site does not allow for product ordering and is simply
informational.
18. DDI has never purposefully directed any action towards Delaware and it could not
reasonably foresee being haled into a Delaware Court.
This day of January, 2008. •
7/i' / /
•
Ehxgoingmi :)1bscr nybefo§ge ?
otary Public A {MM W
(Type or Print Name)
My Commission Expires: G [ @24/J
SABRINA HOOK
w i°$mz
2
CLT 1097865vl

Case 1:07-cv-00753-JJF

Document 46

Filed 01/11/2008

Page 1 of 2

Case 1:07-cv-00753-JJF

Document 46

Filed 01/11/2008

Page 2 of 2