`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF PENNSYLVANIA
`
`
`AMERANTH, INC.
`
`
`
`Plaintiff,
`
`
`v.
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`
`
`DOORDASH, INC.
`
`
`
`Defendant.
`
`
`
`
`)
`)
`) Civil Action No. 2:22-cv-1776-WSH
`)
`)
`)
`)
`)
`)
`)
`
`
`
`
`
`
`
`
`
`
`DECLARATION OF RICHARD C. WEINBLATT
`
`I, Richard C. Weinblatt, pursuant to 28 U.S.C. § 1746, declare as follows:
`
`1.
`
`I am an attorney at Stamoulis & Weinblatt LLC. I submit this declaration in support
`
`of Plaintiff Ameranth, Inc.'s Opposition to Defendant's Motion to Dismiss for Improper Venue, or
`
`Alternatively, to Transfer, and Failure to State a Claim.
`
`2.
`
`I make this declaration based on my own personal knowledge. If called as a
`
`witness, I could and would testify competently to the matters set forth herein.
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`3.
`
`Attached to this declaration as Exhibit A is a true and correct digital printout of Tim
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`Schooley, "DoorDash to make regional debut with DashMart convenience concept on Penn
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`Avenue in Lawrenceville" (Sept. 22, 2021).
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`4.
`
`Attached to this declaration as Exhibit B is a true and correct copy of DoorDash,
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`Inc.'s SEC Form 10-K: Annual Report Pursuant to Section 13 or 15(d) of the Securities Exchange
`
`Act of 1934 For the Fiscal year ended December 31, 2022.
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`5.
`
`Attached to this declaration as Exhibit C is a true and correct digital printout of
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`Andrew Ladd, "Introducing DashMart" (Aug. 5, 2020) from the "DoorDash Newsroom," with text
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`highlighted.
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`
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`Case 2:22-cv-01776-WSH Document 29 Filed 07/20/23 Page 2 of 4
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`6.
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`Attached to this declaration as Exhibit D is a true and correct digital printout of
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`June 9, 2023 DoorDash, Inc. job openings available from the Internet Archive Wayback Machine,
`
`with text highlighted.
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`7.
`
`Attached to this declaration as Exhibit E is a true and correct digital printout of a
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`June 14, 2023 DashMart job posting for "Warehouse Associate - Lower Lawrenceville at
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`DoorDash, Inc."
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`8.
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`Attached to this declaration as Exhibit F is a true and correct digital printout of a
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`June 14, 2023 DashMart job posting for "Shift Lead – Lower Lawrenceville at DoorDash, Inc."
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`9.
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`Attached to this declaration as Exhibit G is a true and correct digital printout of a
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`July 19, 2023 DashMart job posting for " Shift Lead at DoorDash Essentials + Kitchens."
`
`10.
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`Attached to this declaration as Exhibit H is a true and correct digital printout of July
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`19, 2023 DashMart job openings, with text highlighted.
`
`11.
`
`Attached to this declaration as Exhibit I is a true and correct digital printout of the
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`DashMart web page (https://www.doordash.com/dashmart).
`
`12.
`
`Attached to this declaration as Exhibit J is a true and correct digital printout of the
`
`web page
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`that
`
`appears when
`
`clicking on
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`the
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`"About Us"
`
`link
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`found
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`at
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`https://www.doordash.com/dashmart.
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`13.
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`Attached to this declaration as Exhibit K is a true and correct digital printout of the
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`web
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`page
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`that
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`appears when
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`clicking
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`on
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`the
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`"Investors"
`
`link
`
`found
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`at
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`https://www.doordash.com/dashmart.
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`14.
`
`Attached to this declaration as Exhibit L is a true and correct digital printout of the
`
`web page
`
`that appears when clicking on
`
`the "Company Blog"
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`link
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`found at
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`https://www.doordash.com/dashmart.
`
`
`
`2
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`
`
`Case 2:22-cv-01776-WSH Document 29 Filed 07/20/23 Page 3 of 4
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`15.
`
`Attached to this declaration as Exhibit M is a true and correct copy of DoorDash
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`Essential, LLC's State Statement of Information filed with the California Secretary of State on
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`February 2, 2022.
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`16.
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`Attached to this declaration as Exhibit N is a true and correct digital printout of the
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`webpage "Leadership" found at https://doordash.news/leadership/.
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`17.
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`Attached to this declaration as Exhibit O are true and correct digital printouts of
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`June 14, 2023 DashMart job postings for positions "at DoorDash, Inc."
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`18.
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`Attached to this declaration as Exhibit P is a true and correct digital printout from
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`the U.S. Patent and Trademark Office's Trademark Electronic Search System (TESS).
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`19.
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`Attached to this declaration as Exhibit Q are true and correct copies of an October
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`14, 2021 Office Action, November 16, 2021 Response to Office Action, and February 7, 2022
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`Notice of Allowance from the prosecution history of U.S. Patent No. 11,276,130.
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`20.
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`Attached to this declaration as Exhibit R is a true and correct copy of Neonode
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`Smartphone LLC v. Samsung Elecs. Co., 6:20-CV-00507-ADA (W.D. Tex. June 27, 2023),
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`I declare under the penalty of perjury that the foregoing is true and correct. Executed on
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`July 20, 2023.
`
`/s/ Richard C. Weinblatt
`Richard C. Weinblatt
`
`
`
`
`
`3
`
`
`
`Case 2:22-cv-01776-WSH Document 29 Filed 07/20/23 Page 4 of 4
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`CERTIFICATE OF SERVICE
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`I hereby certify that on July 20, 2023, I electronically filed the above document(s) with the
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`Clerk of Court using CM/ECF which will send electronic notification of such filing(s) to all
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`registered counsel.
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`
`
`/s/ Vincent A. Coppola
`Vincent A. Coppola
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`
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`
`
`
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