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`IN THE UNITED STATES DISTRICT COURT
`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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`No. 2:15-CV-01274 (Lead Case)
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`DECLARATION OF ALESSANDRA CARCATERRA MESSING IN SUPPORT OF
`PLAINTIFF BLITZSAFE TEXAS LLC’S RESPONSE TO DEFENDANTS' OPPOSED
`MOTION FOR LEAVE TO SUPPLEMENT INVALIDITY CONTENTIONS
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`I, Alessandra Carcaterra Messing, hereby declare as follows:
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`1.
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`I am an associate at the law firm of Brown Rudnick LLP, counsel for Plaintiff
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`Blitzsafe Texas, LLC (“Plaintiff”). I am admitted to practice before this Court. I submit this
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`declaration in support of Blitzsafe’s Opposition to Defendants’ Motion for Leave to Supplement
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`Invalidity Contentions. I am familiar with the facts set forth herein.
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`2.
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`Attached as Exhibit A is a true and correct copy of Toyota Motor Corporation's
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`Petition for Inter Partes Review of Patent No. 8,155,342 dated December 30, 2015, Case
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`IPR2016-00418 (exemplary of cases IPR2016-00419, IPR2016-00421, and IPR2016-00422).
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`3.
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`Attached as Exhibit B is a true and correct copy of the Declaration of Thomas
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`Matheson, Ph.D. in Support of Petitioner’s Request for Inter Partes Review of Patent No.
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`8,155,342 dated December 30, 2015, Case IPR2016-00418.
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`4.
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` Attached as Exhibit C is a true and correct copy of a Declaration of Ira Marlowe
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`dated August 8, 2016.
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`Case 2:15-cv-01274-JRG-RSP Document 131-1 Filed 08/09/16 Page 2 of 2 PageID #: 3200
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`5.
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`Attached as Exhibit D is a true and correct copy of Honda, Hyundai, Kia, Nissan,
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`and Toyota Defendants' P.R. 3-3 & 3-4 Invalidity Contentions and Disclosures dated January 19,
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`2016.
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`I declare the foregoing to be true under the penalty of perjury on August 8, 2016.
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`_____/s/ Alessandra Carcaterra Messing______
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`Alessandra Carcaterra Messing