Case 2:15-cv-01274-JRG-RSP Document 143-3 Filed 09/12/16 Page 1 of 3 PageID #: 4607
`Case 2:l5—cv—0l274—JRG—RSP Document 143-3 Filed 09/12/16 Page 1 of 3 Page|D #: 4607
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`EXHIBIT C
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`EXHIBIT C
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`Case 2:15-cv-01274-JRG-RSP Document 143-3 Filed 09/12/16 Page 2 of 3 PageID #: 4608
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`PETER LAMBRIANAKOS
`direct dial: (212) 209-4813
`fax: (212) 938-2981
`PLambrianakos@brownrudnick.com
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`August 23, 2016
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`VIA EMAIL (WMANDIR@SUGHRUE.COM)
`
`William H. Mandir, Esq.
`Sughrue Mion PLLC
`2100 Pennsylvania Avenue, NW
`Washington, D.C. 20037
`
`
` RE: Blitzsafe Texas LLC v. Toyota Motor Corp., et al.
`Case No. 2:15-cv-01277-JRG-RSP
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`Dear Bill:
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`We received your letter of August 14, 2016, concerning our associate, Vincent J. Rubino, III, in which you
`contend that “his involvement or consultation in any patent litigation or Inter Partes Review proceeding
`against Toyota would constitute a conflict of interest.” You ask that we confirm that Mr. Rubino has had no
`involvement, and will have no involvement, in Blitzsafe’s district court litigation against Toyota, or Toyota’s
`IPR’s against the Blitzsafe patents.
`
`We have carefully reviewed the case law in the Federal courts and the PTAB and are aware of no basis for
`your allegation that Mr. Rubino’s involvement in these matters would constitute a conflict of interest. Your
`letter identifies no case law and no facts that raise a plausible claim that any conflict of interest would result
`from his involvement in these matters. If you have any specific facts to support a contention that Mr. Rubino
`possesses relevant, confidential information such that there is a reasonable probability that the information
`could be used to Toyota’s disadvantage, we request that you identify that information so that we can assess
`the merits of your request. The general allegations in your letter, even if true, do not approach the standards
`for a conflict of interest in Federal court or the PTAB.
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`Since we assume that you have thoroughly investigated this issue prior to sending your letter, we expect to
`hear from you by the end of the week. If we do not have your reply by August 26, 2016, setting forth specific
`facts and applicable case law, we will assume that this issue is closed.
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`Sincerely,
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`BROWN RUDNICK LLP
`
`Peter Lambrianakos
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`Case 2:15-cv-01274-JRG-RSP Document 143-3 Filed 09/12/16 Page 3 of 3 PageID #: 4609
`William H. Mandir, Esq.
`August 23, 2016
`Page 2
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`John F. Rabena, Esq. - Via Email (jrabena@sughrue.com)
`Brian K. Shelton, Esq. - Via Email (bshelton@sughrue.com)
`Fadi N. Kiblawi, Esq. - Via Email (fkiblawi@sughrue.com)
`Margaret M. Welsh, Esq. - Via Email (mwelsh@sughrue.com)
`J. Thad Heartfield, Esq. - Via Email (thad@heartfieldlawfirm.com)
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`cc: