IN THE UNITED STATES DISTRICT COURT
`FOR THE NORTHERN DISTRICT OF TEXAS
`DALLAS DIVISION
`
`CIVIL ACTION NO. 3:15-cv-2153
`
`JURY TRIAL DEMANDED
`
`
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
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`
`
`GOODSON HOLDINGS, LLC
`
`
`
`Plaintiff,
`
`
`v.
`
`TITEFLEX CORPORATION,
`
`Defendant.
`
`
`
`PLAINTIFF GOODSON HOLDINGS, LLC’S RESPONSES TO
`DEFENDANT TITEFLEX CORPORATION’S FIRST SET OF
` INTERROGATORIES TO (NOS. 1-16)
` 
`Pursuant to Rules 26 and 33 of the Federal Rules of Civil Procedure, Plaintiff Goodson
`
`Holdings, LLC (“Goodson”) serves the following responses to Defendant Titeflex Corporation
`
`(“Titeflex”) First Set of Interrogatories.
`
`DEFINITIONS
`
`1.
`
`Goodson objects to Titeflex’s definition of "Goodson" “you” or “your” to the
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`extent that shall this definition is intended to seek communications to and from Goodson’s
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`attorneys, work product from Goodson attorneys, work by Goodson in anticipation of
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`litigation, or other information which is privileged.
`
`15.
`
`Goodson objects to Titeflex’s definition of “References to any entity” to the
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`extent that shall this definition is intended to seek communications to and from Goodson’s
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`attorneys, work product from Goodson attorneys, work by Goodson in anticipation of
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`litigation, or other information which is privileged.
`
`Goodson Responses to Titeflex’s First Set of Interrogatories
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`
`1
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` 
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` 
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`Titeflex - Exhibit 1034, page 1
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`

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`INSTRUCTIONS
`
`1.
`
`Goodson objects to Titeflex’s Instruction No. 1 to the extent that shall this
`
`instruction is intended to seek communications to and from Goodson’s attorneys, work product
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`from Goodson attorneys, work by Goodson in anticipation of litigation, or other information
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`which is privileged.
`
`2.
`
`When asserting a privilege, Goodson will comply with Federal Rules of Civil
`
`Procedure. Goodson objects to Instruction No. 2 to the extent it varies from the Federal
`
`Rules of Civil Procedure.
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`RESPONSES TO INTERROGATORIES
` 
`
`INTERROGATORY NO. 1:
`
`For each Asserted Claim of the Asserted Patents, describe in detail all facts and
`
`circumstances concerning the claimed dates of conception, priority of invention, reduction to
`
`practice and intervening diligence, including but not limited to: the earliest date to which
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`Goodson claims priority; whether such claimed priority date is based on actual and/or
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`constructive reduction to practice; all evidence corroborating this claim of priority; a specific
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`identification of the earliest actual embodiment(s) of the Asserted Claims if actual reduction to
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`practice is claimed, and/or an identification where each limitation of the Asserted Claim is found
`
`in each patent application constituting a constructive reduction to practice, all intervening
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`diligence from the claimed time of conception to the claimed time of reduction to practice; and
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`all persons who were involved with or otherwise witnessed the alleged conception, actual and/or
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`constructive reduction to practice and intervening diligence.
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`Answer: Goodson has previously produced its documents related to conception and
`
`reduction to practice. Mark Goodson conceived and reduced to practice the inventions claimed in
`
`Goodson Responses to Titeflex’s First Set of Interrogatories
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`2
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`  
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` 
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`Titeflex - Exhibit 1034, page 2
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`

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`the patents-in-suit. Conception and reduction to practice evidence includes Goodson identified a
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`problem with CSST products no later than July 1999 when he published the article Electrically
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`Induced Fuel Gas Fires. GOODSON0000430-31. Goodson also refers Titeflex to the drawings
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`produced as GOODSON0000408-16 and the article produced as GOODSON0000419-28. Mark
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`Goodson conceived his invention beginning in 1999. The invention was actually conceived and
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`reduced to practice no later than December 8, 2004, as evidenced by a fax that was produced as
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`GOODSON0000417-18. Based upon this evidence, Goodson claims a priority date of December
`
`8, 2004. Furthermore, the inventions were constructively reduced to practice no later than July
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`18, 2005, the filing date of application number 11/183,527.
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`INTERROGATORY NO. 2:
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`Separately for each Asserted Claim, describe in detail all facts concerning the first
`
`disclosure of the alleged invention claimed therein, whether the alleged invention was disclosed
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`in whole or in part in such disclosure, such disclosure including the first manufacture, the first
`
`use, the first offer for sale, the first sale, the first description, the first publication or the first
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`public use or knowledge of the alleged invention of the Asserted Claim; your description should
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`include, without limitation, the date on which each such event occurred and an identification of
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`all documents related to such disclosure and all persons with knowledge of such facts.
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`Answer: The first disclosure of the inventions of all of the asserted claims was in
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`application number 11/183, 527 on filed July 18, 2005. Goodson has not manufactured, used,
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`offered for sale any embodiment of the invention. The documents related to this answer are
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`contained in the prosecution history file of the patents-in-suit. The person with knowledge of
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`these facts is Mark Goodson.
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`INTERROGATORY NO. 3:
`
`Identify and describe in detail all communications or discussions, whether direct or
`
`Goodson Responses to Titeflex’s First Set of Interrogatories
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`3
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`Titeflex - Exhibit 1034, page 3
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`

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`indirect, with any third party regarding the Asserted Patents or any Related Patents and
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`Applications, including but not limited to all licenses and offers to license or otherwise obtain or
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`convey any rights to the subject matter of the Asserted Patents or of any Related Patents and
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`Applications, and any negotiations relating to those licenses or offers, whether or not those
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`negotiations resulted in a license or grant of rights; and to the extent that negotiations resulted in
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`such a license or grant of rights, identify all documents relating to such license, grant of rights
`
`and such negotiations, as well as the dates and the names of the parties or signatories of such
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`documents.
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`Answer: In approximately 2010, Goodson and Tracpipe counsel Tim Scanlon had
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`preliminary discussions regarding possible acquisition/licensing and/or utilization of the
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`Goodson patents by Tracipe. No NDA was executed and there was no subsequent discussion.
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`On September 21, 2011, Goodson’s attorney, Jeffrey Degenfelder with the law firm of
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`Carstens & Calhoon LLP sent a letter to Chris Lockhart, Chief Executive Officer of Titeflex
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`Corporation. Mr. Degenfelder advised Titeflex that Goodson owned two patents related to gas
`
`appliance connectors and CSST. He also advised that Goodson was interested in licensing the
`
`technology to Titeflex. Mr. Degenfelder attached copies of the patents-in-suit as well as a
`
`technical article author authored by Mark Goodson regarding the dangers of electrically induced
`
`fires and gas tubing. Titeflex did not obtain a license from Goodson.
`
`On June 26, 2015, Goodson, through its attorney, forwarded to Titeflex a copy of the
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`Complaint, the patents-in-suit, and Mr. Degenfelder’s letter together with an invitation to discuss
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`resolution of the infringement by Titeflex. To date, that invitation has not resulted in a license of
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`the asserted patents. To date, Goodson has not licensed nor offered to license the asserted patent
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`to anyone other than Titeflex.
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`
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`Goodson Responses to Titeflex’s First Set of Interrogatories
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`4
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`Titeflex - Exhibit 1034, page 4
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`

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`In May of 2015, Goodson and counsel had a conference call with IP counsel Mr. Kirk
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`Randolph of Masco / Brass Craft regarding the patents at issue. No agreements were reached.
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`INTERROGATORY NO. 4:
`
`For each Prior Art reference or combination of Prior Art references identified by Titeflex
`
`in its invalidity contentions served on Goodson in this matter and in Titeflex’s petitions for inter
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`partes review of the Asserted Patents before the U.S. Patent Trial and Appeal Board in case
`
`numbers IPR2016-00730 and IPR2016-00731), explain in detail all factual bases why the Prior
`
`Art reference(s) alone or in combination do not invalidate each Asserted Claim, including but not
`
`limited to a claim chart identifying: (1) which elements or limitations are disclosed either
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`explicitly or implicitly in the Prior Art reference(s), and if so, an identification where such
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`elements or limitations are disclosed; and (2) which elements or limitations are not disclosed in
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`the Prior Art reference(s).
`
`Answer: Goodson objects to this interrogatory to the extent that it seeks attorney-client
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`communications or attorney work product. Goodson also objects to this interrogatory on the
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`grounds that it calls for validity expert opinion. Such request is premature at this time. Goodson
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`will provide an expert report in rebuttal to Titeflex invalidity expert report in accordance with the
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`scheduling order entered in this case.
`
`INTERROGATORY NO. 5:
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`State the amount of damages to which you claim to be entitled from Titeflex in this
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`action, whether as lost profits, a reasonable royalty or otherwise, and explain in detail the method
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`used to calculate those damages, including all facts, contentions, anticipated testimony, and
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`documents that you allege support your damages theories, including any royalty rate(s) that you
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`contend constitute a "reasonable royalty" under 35 U.S.C. § 284 for the alleged infringement of
`
`the Asserted Patents and all evidence (including comparable licenses) that you contend
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`Goodson Responses to Titeflex’s First Set of Interrogatories
`
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`5
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` 
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` 
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`
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`Titeflex - Exhibit 1034, page 5
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`substantiates the reasonableness of such a royalty rate.
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`Answer: Goodson objects to this interrogatory to the extent that it seeks attorney-
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`client communications and attorney work product. Goodson seeks a reasonable royalty.
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`Goodson objects to request for calculation of a royalty rate or damages amount at this
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`time for the reason that it calls for expert opinion. Furthermore, the calculation of
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`damages depends in part upon the disclosure by Titeflex of sales and pricing information
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`in response to discovery requests posed by Goodson. Goodson has previously requested
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`pricing and sells information both informally and formally; however, to date, Titeflex is
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`not been forthcoming with this information. Goodson believes that testimony of
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`Titeflex witnesses will be relevant as well as comparable licensing information which
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`may be developed by Goodoson’s expert. Goodson will provide a damages expert
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`report in accordance with the scheduling order entered this case.
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`INTERROGATORY NO. 6:
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`For each Asserted Claim that Goodson contends is willfully infringed by Titeflex,
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`describe in detail the complete factual and legal basis of Goodson’s contention, including an
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`identification of all documents and things that relate to, support, or contradict Goodson’s
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`contention, an identification of every communication or interaction between Titeflex and
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`Goodson that Goodson contends supports its allegation of willfulness, and an identification of
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`each person with knowledge of any facts that support Goodson’s contention and the nature and
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`scope of each person’s knowledge.
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`Answer: On July 1, 2010, Titeflex through its employee, Scott Duquette, advised the
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`United States Patent and Trademark Office that Titeflex was aware of Goodson’s ‘448 patent as
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`well as Goodson’s patent application filed July 18, 2005, and published as US 2007/0012472 on
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`January 18, 2007. On September 21, 2011, Goodson’s attorney, Jeffrey Degenfelder with the
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`Goodson Responses to Titeflex’s First Set of Interrogatories
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`6
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` 
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`
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`Titeflex - Exhibit 1034, page 6
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`law firm of Carstens & Calhoon LLP sent a letter to Chris Lockhart, Chief Executive Officer of
`
`Titeflex Corporation. Mr. Degenfelder advised Titeflex that Goodson owned two patents related
`
`to gas appliance connectors and CSST. He also advised that Goodson was interested in
`
`licensing the technology to Titeflex. Mr. Degenfelder attached copies of the patents-in-suit as
`
`well as a technical article author authored by Mark Goodson regarding the dangers of
`
`electrically induced fires and gas tubing. Despite such knowledge, Titeflex proceeded to
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`manufacture and offer for sale CSST products which infringe the patents-in-suit.
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`INTERROGATORY NO. 7:
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`For each Asserted Claim that Goodson contends that Titeflex infringes, and for which
`
`Goodson alleges there are objective secondary considerations of non-obviousness, describe in
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`detail all factual and legal bases supporting such allegations, the alleged nexus between the
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`alleged secondary consideration and the subject matter recited in the Asserted Claims, and
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`identify all documents, persons, or other evidence concerning such allegations.
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`Answer: Goodson objects to this interrogatory to the extent that it seeks attorney-client
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`communications or attorney work product. Goodson objects to this interrogatory the reason that
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`it seeks expert opinion. Goodson will provide a rebuttal expert report regarding validity in
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`accordance with the scheduling order entered in this case.
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`INTERROGATORY NO. 8:
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`Describe in detail everything ever made, sold, or otherwise offered by Goodson or its
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`licensees, or any previous owners and/or licensees of the Asserted Patents, including, but not
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`limited to any product and/or installation that embodies, practices, was created by practicing, or
`
`uses, in whole or in part, any of the alleged inventions claimed by any of the Asserted Patents,
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`and for each such product and/or installation that practices (or was created by practicing) the
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`alleged inventions, identify the specific claim(s) of each of the Asserted Patents that are/were
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`Goodson Responses to Titeflex’s First Set of Interrogatories
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`7
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`Titeflex - Exhibit 1034, page 7
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`embodied, practiced, or used in the product or installation; identify all persons with knowledge of
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`the design, development, manufacture, structure, operation, and use of the product, installation
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`and/or service; and identify all documents relating to any such product, installation and/or
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`service.
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`
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`Answer: Goodson does not manufacture, sale, nor offered to sell any products. Goodson
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`has not licensed the asserted patents to any third party for any purpose.
`
` 
`INTERROGATORY NO. 9:
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`If Goodson contends that Titeflex contributorily infringed any of the Asserted Patents,
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`state the complete factual basis, identify any supporting documents and describe in detail
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`Goodson’s contributory infringement contentions, which detailed description should include an
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`identification of each claim Goodson contends Titeflex contributorily infringed; specific
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`identification of each direct infringer for each claim Goodson contends Titeflex contributorily
`
`infringed; the basis for Goodson’s contention that Titeflex knew the Accused Instrumentalities
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`were especially made or especially adapted for use in infringement of the Asserted Claims; the
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`basis for Goodson’s contention that the Accused Instrumentalities have no substantial non-
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`infringing uses; and the basis for Goodson’s contention that the Accused Instrumentalities
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`constituted a material part of the alleged invention of the Asserted Claims.
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`Answer: At this time, Goodson has not alleged contributory infringement. Goodson
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`reserves the right to seek leave to amend should written or deposition discovery lead to
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`evidence of contributory infringement.
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`INTERROGATORY NO. 10:
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`If Goodson contends that Titeflex induced infringement of any of the Asserted Patents,
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`state the complete factual basis, identify any supporting documents and describe in detail
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`Goodson Responses to Titeflex’s First Set of Interrogatories
`
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`8
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` 
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`
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`Titeflex - Exhibit 1034, page 8
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`Goodson’s induced infringement contentions, which detailed description should include, at least,
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`an identification of each claim Goodson contends Titeflex induced infringement of; a specific
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`identification of each direct infringer for each claim whom Goodson contends Titeflex induced
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`infringement; the basis for Goodson’s contention that Titeflex had knowledge of or was aware of
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`the Asserted Patents; and the basis for Goodson’s contention that Titeflex knowingly induced
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`infringing acts by the direct infringers.
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`Answer: Titeflex has knowledge of the ‘448 patent as explained in response to
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`Interrogatory No. 6 above. Titeflex manufactures and sells its FlashShield with knowledge that if
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`FlashShield is installed as designed, installers of FlashShield will use methods claimed by the 448
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`patent. Titeflex induces the installers of its products to infringe Claims 1, 2, 3, and 7 of the ‘448
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`patent by instructing installers to install FlashShield using methods claimed by the 448. Titeflex
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`restricts installation of FlashShield to the claimed methods through installer training programs and
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`installer certification requirements which are set out in Titeflex public documents.
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`INTERROGATORY NO. 11:
`
`Describe in detail the utility and advantages of the alleged inventions and/or patented
`
`feature of the Asserted Claims over the prior and alternative modes and methods that had been or
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`are being used for achieving similar results, including without limitation a description of each
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`such prior and alternative modes and methods, identification of all supporting facts, evidence and
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`documents, all persons with knowledge of such facts and evidence, and a description of each
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`such person’s knowledge and the bases for that knowledge.
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`Answer: Goodson is not aware of any prior art or alternative modes and methods which
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`achieve results similar to the inventions of the patents-in-suit. To the extent that this interrogatory
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`seeks comment on prior art asserted by Titeflex, Goodson objects to this interrogatory on the
`
`grounds that it calls for expert opinion. Such request is premature at this time. Goodson will
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`Goodson Responses to Titeflex’s First Set of Interrogatories
`
`
`9
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` 
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`
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`Titeflex - Exhibit 1034, page 9
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`

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` 
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`provide an expert report in rebuttal to Titeflex invalidity expert report in accordance with the
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`scheduling order entered in this case.
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`INTERROGATORY NO. 12:
`
`If you contend that the alleged inventions and/or patented features of the Asserted Claims
`
`are the basis for consumer demand for an Accused Instrumentality or substantially create the
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`value of an Accused Instrumentality or any of its component parts, describe in detail the basis for
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`your contentions, identify all facts, evidence and documents that support your contentions,
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`identify all persons with knowledge of the facts and evidence that support your contentions and
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`describe in detail each such person’s knowledge and the bases for that knowledge.
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`Answer: Goodson’s prior articles regarding gas tubing and connectors outline the defects
`
`of products prior to Goodson’s inventions. The specifications of Goodson’s patent also detail the
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`need for the innovation claimed in the patents-in-suit. Titeflex’s public marketing documents
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`assert the features of the patents-in-suit claims which drive consumer demand. Titeflex’s
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`statements to bodies which issue standards and codes also demonstrate Titeflex’s position that
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`the patented features of the patents-in-suit not only drive consumer demand but are necessary for
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`public safety.
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`To the extent that this interrogatory seeks comment on customer demand as it relates to
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`reasonable royalty, Goodson objects to this interrogatory on the grounds that it calls for expert
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`opinion. Such request is premature at this time. Goodson will provide a damages expert report
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`in accordance with the scheduling order entered in this case.
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` INTERROGATORY NO. 13:
`
`Describe in detail your contention of the extent to which any portion of the value of any
`
`Accused Instrumentality is derived from the alleged inventions and/or patented feature of the
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`Accused Instrumentality and how it should be apportioned between features of the Accused
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`Goodson Responses to Titeflex’s First Set of Interrogatories
`
`
`
`
`10
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`Titeflex - Exhibit 1034, page 10
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`

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`Instrumentality allegedly covered by the Asserted Claims and features of the Accused
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`Instrumentality not covered by the Asserted Claims, and identify all facts, evidence and
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`documents that support your contention, identify all persons with knowledge of the facts and
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`evidence that support your contention and describe in detail each such person’s knowledge and
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`the bases for that knowledge.
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`Answer: Goodson objects to this interrogatory on the grounds that it calls for expert
`
`opinion. Such request is premature at this time. Goodson will provide a damages expert report in
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` 
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`accordance with the scheduling order entered in this case.
`
`INTERROGATORY NO. 14:
`
`Describe in detail when you became aware of each piece of Prior Art cited in Titeflex’s
`
`invalidity contentions served on Goodson in this case and in Titeflex’s petitions for inter partes
`
`review of the Asserted Patents in the U.S. Patent Trial and Appeal Board, case numbers
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`IPR2016-00730 and IPR2016-00731, including Japanese Unexamined Patent Application No.
`
`2003-83482 (“Yamane”) and Japanese Unexamined Patent Application No. 2002-174374
`
`(“Ohki”), and identify all facts, evidence and documents that support your contention, identify all
`
`persons with knowledge of the facts and evidence that support your contention, and describe in
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`detail each such person’s knowledge and the bases for that knowledge.
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`Answer: Goodson objects to this interrogatory for the reason that it calls for attorney-
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`client communications and work product of Goodson’s attorneys who prosecuted the patents-in-
`
`suit as well as Goodson’s attorneys in this case and the pending IPR proceedings. Subject to this
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`objection, Goodson, through it attorneys, was aware of that prior art which it disclosed in the IDS
`
`of the patent prosecution history. Prior to the issuance of the patents-in-suit, Goodson’s attorneys
`
`were not aware of any prior art other than that disclosed in the patent prosecution history. Mark
`
`Goodson personally was not aware of any prior patents or patent applications before the issuance
`
`Goodson Responses to Titeflex’s First Set of Interrogatories
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`
`
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`11
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`Titeflex - Exhibit 1034, page 11
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`

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`of his patents other than that disclosed to him by his prosecution attorneys.
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` 
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` 
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`INTERROGATORY NO. 15:
`
`Describe in detail your contention as to the qualifications of a person having ordinary
`
`skill in the art with respect to the Asserted Claims.
`
`Answer: Goodson agrees that a person of ordinary skill in the art with respect to the
`
`asserted claims would be familiar with basic concepts of lightning protection, either through
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`an undergraduate degree in electrical engineering or comparable subject or from one to three
`
`years of practical work experience designing and installing lightning protection systems.
`
`INTERROGATORY NO. 16:
`
`Provide a detailed description of any and all tests performed to investigate whether the
`
`invention of the Asserted Patents is effective in preventing electrically induced damage to gas
`
`tubing, including its ability to withstand lightning direct and indirect effects. Such description
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`shall include an identification of the product(s) or installation(s) tested, the physical parameters
`
`of such products or installations, the electrical parameters applied (including wave forms), the
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`time and date of such testing, an identification of the persons involved in the creation of the
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`product or installations, an identification of the persons involved in the carrying out and
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`supervision of the tests, and an identification of all documents reflecting such tests, including their
`
`results
`
`Answer: Mark Goodson first performed testing on a Gas Appliance Connector (GAC) in
`
`the timeframe between 1999 and 2004. Documents related to that testing have been produced.
`
`Goodson continues to search for testing and will produce them as they are located. The testing
`
`made use of a Brass Craft GAC, and a HP 3612A power supply. A voltmeter (HP 34401A) was
`
`used also. In a constant current mode, the power supply was used to force ~ 1/2 ampere DC down
`
`the GAC. Measuring the voltage end to end and knowing current gave data that allowed the end to
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`Goodson Responses to Titeflex’s First Set of Interrogatories
`
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`
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`12
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`Titeflex - Exhibit 1034, page 12
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`end resistance to be calculated. From there, resistance calculations were made on copper wire
`
`sizes of wire sizes # 10, 12, and 14 AWG. These calculations showed that theoretically the shunt
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`wire, in parallel with the GAC, would carry about 90% or greater of the fault current that the GAC
`
`would be asked to carry, depending on the AWG of the shunt wire. This initial testing was the
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`basis of the design.
`
`Actual testing of the shunt scheme was then carried out using the ~ 1/ 2 ampere power
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`supply, and a #8 shunt wire. Calculations were then carried out using the #8 shunt wire, and
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`predicted a #8 shunt wire would carry about 98% of the fault current that was flowing through the
`
`combined GAC with a #8 shunt wire attached.
`
`Actual testing at a fault level of 85 amperes was conducted on a GAC with a #10 Cu wire
`
`placed in parallel with the GAC. IE, the #10 wire was acting as the shunt. The power supply was
`
`an EMI brand 300 A DC power supply. Current was measured by way of a Fluke current probe.
`
`The current probe fed a DMM, HPP 34401A. The current forced through the GAC in parallel
`
`with the #10 shunt wire achieved a split of ~ 20:1 (81 amperes through the #10 shunt, 4 amperes
`
`through the GAC.)
`
`This same test setup was also tested with a #14 shunt wire. The measured current split was
`
`15:2, such that 75 amperes flowed in the shunt wire and 10 amperes flowed in the GAC.
`
`These tests were all DC. Mark Goodson performed the tests at Mark Goodson's lab in
`
`Denton. There were no witnesses. This same / similar scheme has been tested since the original
`
`testing on more than one occasion. Mark Goodson is searching for and will produce these
`
`documents.
`
`
`
`Goodson Responses to Titeflex’s First Set of Interrogatories
`
`
`13
`
`
`
`
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`Titeflex - Exhibit 1034, page 13
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`

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`Additional testing information including photos, videos, and documents can be found at
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`www.cssttesting.org, www.safecesst.com, and www.csstdanger.com.
`
`VERIFICATION
`
`I declare that I am properly authorized to execute this verification in connection with
`
`Goodson Holdings LLC’s responses to Defendant Titeflex’s First Set of Interrogatories. I have
`F5“ seul-‘l M E0-
`1-e'v-iew'the responses in the foregoing document and declare under penalty of perjury that the
`
`information provided in the aforesaid responses are based upon personal knowledge and is true and
`
`correct.
`
`Mark E. Goodso
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`Titeflex - Exhibit 1034, page 14
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`

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`Respectfully submitted,
`
`
`_____________________
`Mark D. Strachan
`Texas State Bar No. 19351500
`
` Richard A. Sayles
`
`Texas State Bar No.
`
`SAYLES│WERBNER, P.C.
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`1201 Elm Street, Suite 4400
` Dallas, Texas 75270
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`(214) 939-8700 – Telephone
`(214) 939-8787 – Facsimile
`mstrachan@swtriallaw.com
`dsayles@swtrial.com
`
`N. Scott Carpenter
`Texas State Bar No. 00790428
`Carpenter & Schumacher, P.C.
`2701 Dallas Pkwy., Suite. 570
`Plano, TX 75093-8790
`(972) 403-1133 – Telephone
`(972) 403-0311 – Facsimile
`scarpenter@cstriallaw.com
`
`
`
`Marquette W Wolf
`Texas State Bar No. 00797685
`Ted B. Lyon
`Texas State Bar No. 12741500
`Ted B Lyon & Associates PC
`Town East Tower
`18601 LBJ Frwy, Suite 525
`Mesquite, TX 75150
`(972) 279-6571 – Telephone
`(972) 279-3021 – Facsimile
`mwolf@tedlyon.com
`tlyon@tedlyon.com
`
`
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` ATTORNEYS FOR PLAINTIFF
`GOODSON HOLDINGS, LLC
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`Dated: July 20, 2016.
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`Goodson Responses to Titeflex’s First Set of Interrogatories
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`15
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`Titeflex - Exhibit 1034, page 15
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`CERTIFICATE OF SERVICE
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`I hereby certify that on the 20th day of July, 2016, I electronically served the foregoing
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`document to the attorneys of record for Defendant Titeflex Corporation.
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`_____________________
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`Goodson Responses to Titeflex’s First Set of Interrogatories
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`16
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`Titeflex - Exhibit 1034, page 16
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