`
`IN THE UNITED STATES DISTRICT COURT
`FOR THE WESTERN DISTRICT OF TEXAS
`WACO DIVISION
`
`FLYPSI, INC., (D/B/A FLYP),
`
`Plaintiff,
`
`v.
`
`GOOGLE LLC,
`
`Defendant.
`
`
`
`CIVIL ACTION NO. 6:22-cv-00031-ADA
`
`JURY TRIAL DEMANDED
`
`§
`§
`§
`§
`§
`§
`§
`§
`§
`§
`
`DECLARATION OF ROBERT W. UNIKEL IN SUPPORT OF DEFENDANT GOOGLE
`LLC’S MOTION TO DISMISS PLAINTIFF FLYPSI, INC.’S PRE-SUIT INDIRECT
`AND WILLFUL INFRINGEMENT CLAIMS
`
`I, Robert W. Unikel, declare and state as follows:
`
`1.
`
`I am an attorney with the law firm Paul Hastings LLP and counsel for Defendant
`
`Google LLC (“Google”). I have personal knowledge of the facts contained in this declaration and,
`
`if called upon to do so, I could and would testify competently to the matters set forth herein.
`
`2.
`
`Attached hereto as Exhibit A is a true and correct copy of excerpts from Flyp’s
`
`November 2015 presentation, attached to Flyp’s Second Amended Complaint (Dkt. 103).
`
`3.
`
`Attached hereto as Exhibit B is a true and correct copy of Jordan, Jeff et al., 16
`
`Startup Metrics, ANDREESEN HOROWITZ
`
`(Aug.
`
`21,
`
`2015),
`
`available
`
`at
`
`https://a16z.com/2015/08/21/16-metrics/.
`
`4.
`
`Attached hereto as Exhibit C are true and correct copies of the LinkedIn profiles of
`
`Craig Walker and Wesley Chan.
`
`///
`
`///
`
`
`
`Case 6:22-cv-00031-ADA Document 109-1 Filed 04/12/23 Page 2 of 2
`
`
`
`I declare under penalty of perjury that to the best of my knowledge the foregoing is true
`
`and correct. Executed this 5th day of April, 2023, in Chicago, Illinois.
`
`/s/ Robert W. Unikel
`Robert W. Unikel
`
`
`
`-2-
`
`
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