`
`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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`Case No. 2:15-cv-01274-JRG-RSP
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`JURY TRIAL DEMANDED
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`LEAD CASE
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`§
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`REPLY DECLARATION OF JOHN F. RABENA, ESQ ISO
`DEFENDANTS' MOTION FOR LEAVE TO
`SUPPLEMENT INVALIDITY CONTENTIONS
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`I, John F. Rabena, declare:
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`1. I am a lawyer with the firm of Sughrue Mion, PLLC (“Sughrue”). Sughrue represents
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`defendants Toyota Motor Corporation, Toyota Motor Sales USA Inc., Toyota Motor
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`Manufacturing Texas, Inc., Toyota Motor Manufacturing Kentucky, Inc., and Toyota Motor
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`Manufacturing Mississippi, Inc. in the above consolidated case.
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`2. I submit this declaration in support of Defendants’ Reply ISO Their Motion for Leave to
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`Supplement Invalidity Contentions. I have been admitted pro hac vice in this case, and I am
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`familiar with and have personal knowledge of the procedures and practices of the United
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`States District Court for the Eastern District of Texas. The statements of fact made in this
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`declaration are based on my personal knowledge.
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`3. Attached as Exhibit 21 is a true and correct copy of a Discovery Confidentiality Order
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`entered in the case Marlowe Patent Holdings LLC, v. Ford Motor Company, 3:11-cv-07044-
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`PGS-DEA (D. NJ).
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`Case 2:15-cv-01274-JRG-RSP Document 134-1 Filed 08/18/16 Page 2 of 2 PageID #: 4290
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`4. Mr. Edward Fischer represented to me in a telephone call that he had not retained copies of
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`the prior art TOY/PAN source code after producing it in the prior litigation, because he was
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`afraid of repercussions from Mr. Marlowe.
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`5. Attached as Exhibit 22 is a true and correct copy of an Order Dismissing Case with
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`Prejudice in Marlowe Patent Holdings LLC, v. Ford Motor Company, 3:11-cv-07044-PGS-
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`DEA (D. NJ) dated June 1, 2015.
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` I
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` declare under penalty of perjury that the foregoing is true and correct.
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`_____________________
`John F. Rabena
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`2
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`Dated: August 18, 2016
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