`
`Benjamin T. Horton
`Tron Y. Fu
`MARSHALL, GERSTEIN & BORUN LLP
`233 South Wacker Drive
`6300 Willis Tower
`Chicago, IL 60606-6357
`(312) 474-6300
`E: bhorton@marshallip.com
`E: tfu@marshallip.com
`
`Attorneys for Defendant Cars.com
`
`UNITED STATES DISTRICT COURT
`
`NORTHERN DISTRICT OF CALIFORNIA
`
`SAN JOSE
`
`IN RE: PERSONALWEB TECHNOLOGIES, LLC
`et al., PATENT LITIGATION
`
`MULTI-DISTRICT LITIGATION
`Case No. 5:18-md-02834-BLF
`
`PERSONALWEB TECHNOLOGIES, LLC, a Texas
`limited liability company, and
`LEVEL 3 COMMUNICATIONS, LLC, a Delaware
`limited liability company,
`
`Plaintiffs,
`
`v.
`
`DECLARATION OF TRON Y. FU IN
`SUPPORT OF CARS.COM’S
`ADMINISTRATIVE MOTION TO
`APPEAR TELEPHONICALLY FOR
`CASE MANAGEMENT
`CONFERENCE
`
`CARS.COM, a Delaware Corporation,
`
`Case No. 1:18-cv-01140-GMS
`
`Defendant.
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`Case 5:18-md-02834-BLF Document 274-1 Filed 10/30/18 Page 2 of 2
`
`DECLARATION OF TRON Y. FU
`
`I, Tron Y. Fu, hereby declare as follows:
`
`1.
`
`I am an attorney duly admitted to practice before this Court and an associate of
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`Marshall, Gerstein & Borun LLP, counsel of record for Defendant Cars.com (“Cars”) in the above
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`captioned case. I have personal knowledge of the matters stated below and, if called as a witness, I
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`could competently testify thereto.
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`2.
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`Benjamin T. Horton and Tron Fu, two of the attorneys of record for Cars.com, reside
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`in the Chicago area.
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`3.
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`Live appearances by the above-mentioned Midwest counsel for Cars.com are not
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`feasible because of the time and expense involved, requiring 13 to 18 hours of travel and an
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`overnight stay.
`
`4.
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`As one of the customer cases currently stayed while the Court proceeds with the
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`Amazon DJ action, Cars.com anticipates limited involvement required of its counsel at the Case
`
`Management Conference scheduled to be held November 2, 2018 at 9 am.
`
`5.
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`Counsel for Cars.com has inquired whether Plaintiffs object to this request and have
`
`been informed that Plaintiffs do not object.
`
`I declare under penalty of perjury under the laws of the United States of America that the
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`foregoing is true and correct, and that this declaration is executed on October 30, 2018 at Chicago,
`
`Illinois.
`
`Date: October 30, 2018
`
`By:
`
`/s/ Tron Y. Fu
`Tron Y. Fu
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