Case 2:17-cv-01104-RSL Document 2-3 Filed 07/20/17 Page 1 of 3

1 The Honorable _________________

2
3
4

5
6
7
UNITED STATES DISTRICT COURT
8 WESTERN DISTRICT OF WASHINGTON
AT SEATTLE
9
10 Cung Le, Nathan Quarry, Jon Fitch,
Brandon Vera, Luis Javier Vazquez, 2:17-mc-00074 RSL
No. _________________
11 and Kyle Kingsbury on behalf of themselves
and all others similarly situated, DECLARATION OF VICTOR CHU
12 IN SUPPORT OF NONPARTIES
Plaintiffs, MATT HUME AND GROUP ONE
13 HOLDINGS PTE LTD.S MOTION
v. TO QUASH FOREIGN SUBPOENAS
14 ISSUED BY PLAINTIFFS
Zuffa, LLC, d/b/a Ultimate Fighting
15 Championship and UFC,
Issuing Court: District of Nevada
16 Defendant,
Underlying Action: Le et al. v. Zuffa,
17 LLC, Civ. Act. No. 2:15-cv-01045-
Matt Hume and Group One Holdings Pte Ltd. RFB-PAL
18 d/b/a/ One Championship,
19 Nonparty Movants.
20
21
I, Victor Chu, hereby declare and state as follows:
22

23 1. I am Senior Vice President of Client Servicing & Strategic Partnerships for

24 Group One Holdings Pte Ltd. I have personal knowledge of the matters set forth in this
25 declaration. If called to testify to these matters, I could do so competently.
26
27
DECLARATION IN SUPPORT OF MOTION TO QUASH SUBPOENA TO
NONPARTY MATT HUME
Davis Wright Tremaine LLP
-1 L A W O F FI C ES
4830-4369-4411v.1 0107701-000001 1201 Third Avenue, Suite 2200
Seattle, WA 98101-3045
206.622.3150 main 206.757.7700 fax
 Case 2:17-cv-01104-RSL Document 2-3 Filed 07/20/17 Page 2 of 3

1 2. Group One. Group One Holdings Pte Ltd. (Group One) is a Singaporean

2 company that operates ONE Championshipa mixed martial arts fight promotion

3 organization. Group One does not operate or transact business in the United States.

4 3. Group Ones Proprietary Information. In the course of doing business, Group

5 One creates and maintains documents, including emails and other communications, which

6 include confidential and trade secret information. These documents may be created by Group

7 Ones executives, or by its lower level employees, but they belong to Group One. Many of

8 these documents are kept on computers or in physical files which Group Ones employees use

9 in their employment. In the course of their employment, Group Ones employees may access

10 these documents from, or store these documents in Group Ones Singaporean office, the

11 employees home office, or an office separate from Group Ones Singaporean office.

12 Employees may even access or transmit these documents while travelling in the scope of their

13 employment. But at no point do the employees take possession of Group Ones documents,

14 which remain Group Ones property at all times.

15 4. Group Ones Confidentiality Precautions. Group One takes precautions to

16 ensure that its confidential company information, including the documents sought by the

17 document subpoena to Mr. Hume, are not shared outside Group One. Even within the

18 company, Group One restricts access to the information to certain high-level employees and

19 officers. Group One requires employees with access to confidential information to enter

20 confidentiality agreements prohibiting disclosure to third-parties. Mr. Hume is subject to such

21 a confidentiality agreement.

22 5. Document Requests. I have reviewed the subpoena directed to Matt Hume in

23 the Le v. Zuffa lawsuit and the document requests attached as Schedule A. I am familiar with

24 the categories of documents sought by those requests. Many of the requests, including

25 Requests 1, 2, 3, 4, 5, 6, 7, 8, 9, 13, and 14, seek documents belonging to Group One and which

26 contain the companys confidential, proprietary and commercially-sensitive information.

27
DECLARATION IN SUPPORT OF MOTION TO QUASH SUBPOENA TO
NONPARTY MATT HUME
Davis Wright Tremaine LLP
-2 L A W O F FI C ES
4830-4369-4411v.1 0107701-000001 1201 Third Avenue, Suite 2200
Seattle, WA 98101-3045
206.622.3150 main 206.757.7700 fax
 Case 2:17-cv-01104-RSL Document 2-3 Filed 07/20/17 Page 3 of 3

1 6. Competitive Risk of Disclosure. The documents sought by these requests, if

2 made public or otherwise disclosed to a competitor, could substantially harm Group Ones

3 competitive standing. Those requests seek confidential and commercially-valuable information

4 about Group Ones internal business operations and strategy. For example, Request No. 6

5 seeks documents containing detailed information about Group Ones fight promotion strategy,

6 compensation paid to fighters, revenue received from fight promotions, advertising,

7 broadcasting, and merchandise, as well as the costs associated with promoting MMA events.

8 Request No. 14 encompasses, among other things, Group Ones strategic business plans,

9 competitive analyses, budgets and other financial data. If the information in those documents

10 were made public or disclosed to a competitor, Group One would suffer substantial and

11 irreparable competitive harm because the information could provide a competitor an unfair and

12 unearned advantage in the marketplace that could be used to Group Ones detriment.

13 7. Matt Hume. Matt Hume is a valued Group One employee, but he is not a senior

14 executive, does not have authority to determine whether confidential information may be

15 shared outside of Group One, and is not authorized to comment publicly on behalf of Group

16 One. Mr. Hume has no right to obtain or release Group Ones documents or information on

17 demand. Mr. Hume has access to Group Ones confidential documents and information by

18 virtue of his employment, and only to documents and information necessary for his

19 employment, and his access to that information is conditioned on his agreement not to disclose

20 the information outside of Group One.

21 I declare under penalty of perjury under the laws of the State of Washington that the

22 foregoing is true and correct to the best of my knowledge and belief.

23 Executed in ______________________,
Vancouver, BC, Canada this ____
19 day of July, 2017.

24
By ________
25
Victor Chu
26
27
DECLARATION IN SUPPORT OF MOTION TO QUASH SUBPOENA TO
NONPARTY MATT HUME
Davis Wright Tremaine LLP
-3 L A W O F FI C ES
4830-4369-4411v.1 0107701-000001 1201 Third Avenue, Suite 2200
Seattle, WA 98101-3045
206.622.3150 main 206.757.7700 fax