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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 PETER LAMBRIANAKOS IN SUPPORT OF PLAINTIFF’S
`RESPONSE IN OPPOSITION TO DEFENDANTS’ MOTION TO STAY
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`I, Peter Lambrianakos, hereby declare as follows:
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`1.
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`I am a partner 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 Plaintiff’s Response in Opposition to Defendants’ Motion Stay. I am
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`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 the petition filed on October
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`30, 2015, by Unified Patents Inc. against certain claims of U.S. Patent No. 8,155,342 in
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`IPR2016-00118.
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`3.
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`Attached as Exhibit B is a true and correct copy of a proposed stipulation filed on
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`March 15, 2016, by Unified Patents Inc. in IPR2016-00118.
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`4.
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`Attached as Exhibit C is a true and correct copy of the order denying institution of
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`IPR2016-00118 entered by the PTAB on April 27, 2016.
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`5.
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`Attached as Exhibit D is a true and correct copy of the order denying institution of
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`IPR2016-00422 entered by the PTAB on July 6, 2016.
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`Case 2:15-cv-01274-JRG-RSP Document 142-1 Filed 09/01/16 Page 2 of 2 PageID #: 4401
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`6.
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`Attached as Exhibit E is a true and correct copy of the order denying institution of
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`IPR2016-00419 entered by the PTAB on July 19, 2016.
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`I declare under penalty of perjury that the foregoing is true and correct. Executed this 1st
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` /s/ Peter Lambrianakos
`Peter Lambrianakos
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`2
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`day of September, 2016.
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