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Case 2:22-cv-00303-JRG Document 65 Filed 02/22/23 Page 1 of 3 PageID #: 242
`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE EASTERN DISTRICT OF TEXAS
`MARSHALL DIVISION
`
`IN RE: TAASERA LICENSING LLC,
`PATENT LITIGATION
`
`THIS DOCUMENT RELATES TO:
`CASE NO. 2:22-cv-00303-JRG
`CASE NO. 2:21-cv-00441-JRG
`
`
`TREND MICRO, INC.,
`
`
`
`
`Plaintiff,
`
`
`v.
`
`TAASERA LICENSING LLC,
`
`
`
`Defendant.
`
`
`
`TAASERA LICENSING LLC,
`
`
`
`
`Plaintiff,
`
`
`v.
`
`TREND MICRO, INC.,
`
`
`
`Defendant.
`
`
`
`
`Case No. 2:22-md-03042-JRG
`
`
`
`
`Case No. 2:22-cv-00303-JRG
`
`JURY TRIAL DEMANDED
`
`
`
`
`Case No. 2:21-cv-00441-JRG
`
`JURY TRIAL DEMANDED
`
`NOTICE TO CLARIFY THE RECORD
`
`During oral argument on February 21, 2023, counsel for Trend Micro Incorporated (“Trend
`
`
`
`
`
`
`
`Micro Japan”) explained the corporate structure between the various Trend Micro entities. To the
`
`extent the record suggests that Trend Micro Japan holds or owns the assets of the mentioned
`
`subsidiaries, that is not accurate. Counsel was merely attempting to distinguish between Trend
`
`Micro Japan’s operations in Japan, as opposed to its ownership of shares in Trend Micro America,
`
`Inc. As detailed in Trend Micro, Inc.’s (“Trend Micro U.S.”) Rule 7.1 Disclosure Statement filed
`
`in Case No. 2:22-cv-00303-JRG (Dkt. No. 3), Trend Micro America, Inc. is a wholly-owned
`
`subsidiary of Trend Micro Japan. Trend Micro U.S. is a wholly-owned subsidiary of Trend Micro
`
`DM2\17386608.1
`
`

`

`Case 2:22-cv-00303-JRG Document 65 Filed 02/22/23 Page 2 of 3 PageID #: 243
`
`America, Inc. Counsel’s understanding is that Trend Micro Japan, Trend Micro America, Inc., and
`
`Trend Micro U.S. are distinct corporate entities and observe separate corporate formalities.
`
`Dated: February 22, 2023
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`/s/ Melissa R. Smith
`Melissa R. Smith
`Texas State Bar No. 07921800
`GILLAM & SMITH, LLP
`303 S. Washington Ave.
`Marshall, TX 75670
`Telephone: (903) 934-8450
`Facsimile: (903) 934-9257
`melissa@gillamsmithlaw.com
`
`Holly Engelmann
`Texas State Bar No. 24040865
`DUANE MORRIS LLP
`100 Crescent Court, Suite 1200
`Dallas, Texas 75201
`Telephone: (214) 257-7200
`Facsimile: (214) 257-7201
`hengelmann@duanemorris.com
`
`D. Stuart Bartow
`DUANE MORRIS LLP
`2475 Hanover Street
`Palo Alto, CA 94304
`Telephone: (650) 847-4150
`Facsimile: (650) 618-8505
`dsbartow@duanemorris.com
`
`Counsel for DJ Plaintiff Trend Micro, Inc.
`(U.S..) and Defendant Trend Micro,
`Incorporated (Japan)
`
`
`
`
`
`
`DM2\17386608.1
`
`2
`
`

`

`Case 2:22-cv-00303-JRG Document 65 Filed 02/22/23 Page 3 of 3 PageID #: 244
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies that the foregoing document was filed electronically in
`
`compliance with Local Rule CV-5(a). Plaintiff’s counsel of record was served with a true and
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`correct copy of the foregoing document by electronic mail on February 22, 2023.
`
`
`
`
`
`
`
`
`
`
`
`/s/ Melissa R. Smith
`
`
`
`
`DM2\17386608.1
`
`3
`
`

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