`Case 2:l5—cv—0l274—JRG—RSP Document 130-4 Filed 08/08/16 Page 1 of 3 Page|D #: 3149
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`EXHIBIT C
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`EXHIBIT C
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`Case 2:15-cv-01274-JRG-RSP Document 130-4 Filed 08/08/16 Page 2 of 3 PageID #: 3150
`Case 2:15—cv—O1274—JRG—RSP Document 130-4 Filed 08/08/16 Page 2 of 3 Page|D #: 3150
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`IN THE UNITED STATES DISTRICT COURT
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`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`BLITZSAFE TEXAS, LLC,
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`Plaintiff,
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`v.
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`HONDA MOTOR CO., LTD, et al.,
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`Defendants.
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`<030O3<oO'>P4O'J<4O0<aO'>0O'3<0'3<aO><AO'><02
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`No. 2: 1 5-CV-01274 (Lead Case)
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`DECLARATION OF IRA MARLOWE
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`I, Ira Marlowe, hereby declare as follows:
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`1.
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`I am the President of Blitzsafe Texas, LLC and the inventor of U.S. Patents
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`7,489,786 and 8,155,342. Also, I was a member of B1itzsafe’s predecessor, Marlowe Patent
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`Holdings LLC.
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`2.
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`Neither I nor Blitzsafe Texas, LLC has ever received a copy of the TOY/PAN
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`source code from Mr. Kun Cho.
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`I have been made aware that Mr. Cho viewed the source code
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`during his time representing Marlowe Patent Holdings LLC, but he never sent me this source
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`code.
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`3.
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`Blitzsafe has a copy of the TOY/PAN source code in its possession that was first
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`sent to me by my attorneys on July 18, 2016. My understanding is that this code was produced
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`to my attorneys as the result of Defendants’ subpoena to Ford Motor Company in this litigation.
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`Blitzsafe did not have possession of this code prior to receiving it from my attorneys in this
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`litigation on July 18, 2016.
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`Case 2:15-cv-01274-JRG-RSP Document 130-4 Filed 08/08/16 Page 3 of 3 PageID #: 3151
`Case 2:15—cv—O1274—JRG—RSP Document 130-4 Filed 08/08/16 Page 3 of 3 Page|D #: 3151
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`I declare under the penalty of perjury that the foregoing to be true and correct. Executed
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`on August 8. 2016 in Englewood, New Jersey.
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` arlowe