`
`
`
`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
`
`
`
`PERSONALWEB TECHNOLOGIES, LLC, a Texas
`limited liability company, and
`LEVEL 3 COMMUNICATIONS, LLC, a Delaware
`limited liability company,
`
`
`
`
`
`Plaintiffs,
`
`
`
`v.
`
`CARS.COM, a Delaware Corporation,
`
`
`
`
` MULTI-DISTRICT LITIGATION
`
`Case No. 5:18-md-02834-BLF
`
`
`
`DECLARATION OF JOHN J. LUCAS
`IN SUPPORT OF CARS.COM’S
`ADMINISTRATIVE MOTION TO
`APPEAR TELEPHONICALLY FOR
`CLAIM CONSTRUCTIN TUTORIAL
`ON MAY 2, 2019
`
`
`Case No. 1:18-cv-01140-GMS
`
`
`
`
`
`Defendant.
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`Case 5:18-md-02834-BLF Document 419-1 Filed 04/29/19 Page 2 of 2
`
`
`
`DECLARATION OF JOHN J. LUCAS
`
`I, John J. Lucas, hereby declare as follows:
`
`1.
`
`I am an attorney duly admitted to practice before this Court and an associate of
`
`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
`
`could competently testify thereto.
`
`2.
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`Benjamin T. Horton and John J. Lucas, two of the attorneys of record for Cars.com,
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`reside 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.
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`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 Claim
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`14
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`Construction Tutorial scheduled to be held May 2, 2019 at 2:00 p.m.
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`5.
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`Counsel for Cars.com has inquired whether Plaintiffs object to this request and have
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`been informed that Plaintiffs do not object.
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`17
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`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 April 29, 2019 at Chicago,
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`19
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`Illinois.
`
`
`Date: April 29, 2019
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`By:
`
`/s/ John J. Lucas
`John J. Lucas
`
`-2-
`
`
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