`Case 2:l5—cv—0l274—JRG—RSP Document 88-4 Filed 04/01/16 Page 1 of 4 Page|D #: 1252
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`EXHIBIT D
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`EXHIBIT D
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`Case 2:15-cv-01274-JRG-RSP Document 88-4 Filed 04/01/16 Page 2 of 4 PageID #: 1253
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`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
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`Case No. 2:15-CV-1274-JRG-RSP
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`(LEAD CASE)
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`JURY TRIAL DEMANDED
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`§
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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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`PRELIMINARY IDENTIFICATION OF EXPERT TESTIMONY
`REGARDING INDEFNITENESS CHALLENGE
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`Pursuant to Patent Rule 4-3 and the Court’s Docket Control Order of January 8, 2016
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`(Dkt. 56), Plaintiff Blitzsafe Texas, LLC, being subject to an indefiniteness challenge,
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`provides a preliminary identification of expert testimony it may rely on its response to any
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`such indefiniteness challenge brought by Defendants and a brief description of the proposed
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`testimony. Plaintiff reserves the right to supplement this information as additional information
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`becomes available or should the scope of the cases or issues change. Plaintiff further reserves the
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`right to supplement this information to identify additional expert witnesses or testimony to rebut
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`any expert testimony or factual testimony offered by Defendants.
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`Mr. Joseph McAlexander has expertise in various areas, including those generally
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`described in his curriculum vitae, which has been separately provided to Defendants. He intends
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`to provide testimony regarding the understanding of one of ordinary skill in the art at the
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`time of the inventions at issue relevant to the asserted claims of the U.S. Patent Nos. 7,489,786
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`Case 2:15-cv-01274-JRG-RSP Document 88-4 Filed 04/01/16 Page 3 of 4 PageID #: 1254
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`(the “’786 patent”) and 8,155,342 (the “’342 patent”) and any indefiniteness challenges to the
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`asserted claims.
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`Mr. McAlexander may opine on any position taken by Defendants’ experts related
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`to an indefiniteness challenge to the ’342 patent. In particular, Mr. McAlexander may opine on
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`whether the term “integration subsystem” would have been understood by persons of ordinary
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`skill in the art to have a sufficiently definite meaning as the name for structure. Mr.
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`McAlexander may also opine on whether the claims and/or the specification of the ’342 patent
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`disclose sufficient structure to one of ordinary skill in the art for performing any alleged
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`functions of the claims as proposed by Defendants, such as, for example, the structure identified
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`in Plaintiff’s chart accompanying this disclosure as Exhibit A.
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`-2-
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`Case 2:15-cv-01274-JRG-RSP Document 88-4 Filed 04/01/16 Page 4 of 4 PageID #: 1255
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`Dated: April 1, 2016
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`BROWN RUDNICK LLP
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` /s/ Peter Lambrianakos
`Alfred R. Fabricant
`Texas Bar No. 2219392
`Email: afabricant@brownrudnick.com
`Lawrence C. Drucker
`Email: ldrucker@brownrudnick.com
`Texas Bar No. 2303089
`Peter Lambrianakos
`Texas Bar No. 2894392
`Email: plambrianakos@brownrudnick.com
`Alessandra Carcaterra Messing
`(admitted pro hac vice)
`Email: amessing@brownrudnick.com
`BROWN RUDNICK LLP
`7 Times Square
`New York, NY 10036
`Telephone: (212) 209-4800
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`Samuel F. Baxter
`Texas State Bar No. 01938000
`sbaxter@mckoolsmith.com
`Jennifer L. Truelove
`Texas State Bar No. 24012906
`jtruelove@mckoolsmith.com
`MCKOOL SMITH, P.C.
`104 E. Houston Street, Suite 300
`Marshall, Texas 75670
`Telephone: (903) 923-9000
`Facsimile: (903) 923-9099
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`ATTORNEYS FOR PLAINTIFF,
`BLITZSAFE TEXAS, LLC
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`62440997 v1-WorkSiteUS-032437/0001
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`-3-
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