`Case 2:15—cv—01274—JRG—RSP Document 143-2 Filed 09/12/16 Page 1 of 2 Page|D #: 4605
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`EXHIBIT B
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`EXHIBIT B
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`Case 2:15-cv-01274-JRG-RSP Document 143-2 Filed 09/12/16 Page 2 of 2 PageID #: 4606
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`2100 Pennsylvania Avenue, NW
`Washington, DC 20037-3213
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`T 202.293.7060
`F 202.293.7860
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`www.sughrue.com
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`August 14, 2016
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`VIA EMAIL
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`William H. MandirWilliam H. MandirWilliam H. Mandir William H. Mandir
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`T 202.663.7959
`wmandir@sughrue.com
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`Peter Lambrianakos
`Brown Rudnick LLP
`Seven Times Square
`New York, NY 10036
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`Blitzsafe Texas, LLC v. Toyota Motor Corp., et al
`Case No. 2:15-cv-1277-JRG-RSP
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`Dear Peter:
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`We are writing because it has come to our attention that Mr. Vincent Rubino recently
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`took the deposition of a 30(b)(6) witness in Blitzsafe's district court litigation against Honda.
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`As you probably know, Mr. Rubino was formerly an associate with the law firm of
`Kenyon & Kenyon prior to joining your firm. As you also probably know, while at Kenyon, Mr.
`Rubino was involved in representing Toyota in numerous patent litigations. As a result of these
`patent litigations, Mr. Rubino was privy to Toyota's defense strategies as well as numerous other
`confidential and privileged documents and communications. He also had meetings involving
`defense strategies with at least one of Toyota's designated 30(b)(6) witnesses. As a result of Mr.
`Rubino's prior representation of Toyota, it is our view that his involvement or consultation in any
`patent litigation or Inter Partes Review proceeding against Toyota would constitute a conflict of
`interest.
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`Therefore, we request that you immediately confirm that Mr. Rubino has not been
`involved with or consulted in Blitzsafe's district court litigation against Toyota, or the pending
`IPRs involving Toyota. Further, we request that you immediately confirm that Mr. Rubino will
`not in the future become involved or consult with others in any aspect of Blitzsafe's litigation
`against Toyota or the IPRs filed by Toyota.
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`We look forward to your response.
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`WHM:gbh
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`Very truly yours,
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`William H. Mandir
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`Washington, DC ~ Tokyo
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