IN THE UNITED STATES DISTRICT COURT 

FOR THE WESTERN DISTRICT OF TEXAS 

WACO DIVISION 

PASAFESHARE LLC , 

 Plaintiff, 

 V. 

MICROSOFT CORPORATION, 

 Defendant. 

Case No. 6:20-CV-00397-ADA 

 JURY TRIAL DEMANDED 

PLAINTIFF PASAFESHARE LLC’S OPPOSITION TO DEFENDANT MICROSOFT 

CORPORATION’S MOTION FOR INTRA-DISTRICT TRANSFER OF VENUE 

TO THE AUSTIN DIVISION OF THE WESTERN DISTRICT OF TEXAS 

Case 6:20-cv-00397-ADA Document 28 Filed 09/25/20 Page 1 of 15
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TABLE OF CONTENTS 

I. Introduction. ........................................................................................................................ 1

II. Background. ........................................................................................................................ 2

III. Legal standard. .................................................................................................................... 3

IV. Argument. ........................................................................................................................... 4

A. The private interest factors weigh against transfer. ................................................ 5

1. The sources of proof are not more conveniently located in Austin. ................ 5

2. Microsoft fails to show that the cost of attendance for willing 

witnesses favors transfer. ................................................................................. 7

3. All other practical problems weigh against transfer. ........................................ 9

B. The public interest factors weigh against transfer. ............................................... 10

1. The local interest factor. ................................................................................. 10

V. Conclusion. ....................................................................................................................... 11

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TABLE OF AUTHORITIES 

Page(s) 

Cases 

Action Indus., Inc. v. U.S. Fid. & Guar. Co., 

358 F.3d 337 (5th Cir. 2004) .....................................................................................................4 

Babbage Holdings, LLC v. 505 Games (U.S.), Inc., 

2014 U.S. Dist. LEXIS 139195 (E.D. Tex. Oct. 1, 2014) .........................................................1 

Durrett v. Walmart, Inc., 

2018 U.S. Dist. LEXIS 186618 (E.D. Tex. Oct. 31, 2018) ...................................................5, 7 

Fintiv, Inc. v. Apple Inc., 

2019 U.S. Dist. LEXIS 171102 (W.D. Tex. Sep. 10, 2019) ..................................................5, 7 

Found. Med., Inc. v. Guardant Health, Inc., 

2017 U.S. Dist. LEXIS 20431 (E.D. Tex. Feb. 14, 2017) .......................................................10 

In re Genentech, Inc., 

566 F.3d 1338 (Fed. Cir. 2009)..................................................................................................1 

Hammond Dev. Int'l, Inc. v. Google LLC, 

2020 U.S. Dist. LEXIS 110984 (W.D. Tex. June 24, 2020)......................................................8 

Hoffman v. Blaski, 

363 U.S. 335 (1960) ...................................................................................................................4 

LBS Innovations, LLC v. Apple Inc., 

2020 U.S. Dist. LEXIS 33064 (E.D. Tex. Feb. 26, 2020) .........................................................8 

Nat’l Cheng Kung Univ. v. Intel Corp., 

2014 U.S. Dist. LEXIS 135683 (E.D. Tex. Sep. 26, 2014) .......................................................8 

RPB Safety, LLC v. Tru-Vision Plastics, Inc., 

2019 U.S. Dist. LEXIS 233382 (W.D. Tex. Feb. 20, 2019) ......................................................9 

Silvertson v. Clinton, 

2011 U.S. Dist. LEXIS 104097 (N.D. Tex. Sept. 14, 2011) ......................................................7 

Stewart Org., Inc. v. Ricoh Corp., 

487 U.S. 22 (1988) .....................................................................................................................3 

Uniloc 2017 LLC v. Apple Inc., 

2020 U.S. Dist. LEXIS 109037 (W.D. Tex. June 19, 2020)......................................................1 

Case 6:20-cv-00397-ADA Document 28 Filed 09/25/20 Page 3 of 15
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In re Volkswagen AG, 

371 F.3d 201 (5th Cir. 2004) ...............................................................................................4, 10 

In re Volkswagen of America, Inc., 

545 F.3d 304 (5th Cir. 2008) .........................................................................................3, 4, 7, 9 

Case 6:20-cv-00397-ADA Document 28 Filed 09/25/20 Page 4 of 15
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Plaintiff paSafeShare LLC (“Plaintiff” or “paSafeShare”) submits this Opposition in 

response to Defendant Microsoft Corporation’s (“Defendant” or “Microsoft”) Opposed Motion 

For Intra-District Transfer of Venue to the Austin Division of the Western District of Texas. For 

the following reasons, Plaintiff respectfully requests that Defendant’s Motion be denied. 

I. Introduction. 

Microsoft carries a significant burden seeking a transfer to an allegedly more convenient 

forum. See Uniloc 2017 LLC v. Apple Inc., 2020 U.S. Dist. LEXIS 109037, at *2 (W.D. Tex. 

June 19, 2020) (citing Babbage Holdings, LLC v. 505 Games (U.S.), Inc., 2014 U.S. Dist. LEXIS 

139195, at *12-14 (E.D. Tex. Oct. 1, 2014)). Not only must Microsoft show that the facts 

support transfer under the applicable legal standard, but it bears the evidentiary burden of 

establishing the desired forum “is clearly more convenient than the forum where the case was 

filed.” Babbage Holdings, 2014 U.S. Dist. LEXIS 139195, at *13-14. Microsoft’s motion, 

however, falls woefully short of meeting this “significant” burden. Microsoft relies extensively 

on speculation—the mere possibility of documents and/or witnesses located in Austin—to show 

that the Austin Division is clearly more convenient than the Waco Division. In fact, Microsoft 

makes no attempt to identify any particular witness in Austin by name, title, responsibility or 

relevance. Microsoft also completely ignores third-party witnesses, despite the overwhelming 

importance of non-party witnesses in the transfer analysis. In re Genentech, Inc., 566 F.3d 1338, 

1343 (Fed. Cir. 2009) (“The convenience of the witnesses is probably the single most important 

factor in transfer analysis.”). 

Microsoft’s arguments about paSafeShare not having any connection to this Division are 

also misplaced, and turn the relevant burden on its head. Microsoft wrongly suggests that 

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paSafeShare bears a burden in showing that the Waco Division is a convenient forum to litigate 

this case and that it must have ties to Waco. But of course, that is not correct. From a 

plaintiff/patentee’s perspective, after TC Heartland, a proper choice of forum under § 1400(b) is 

where the defendant has an established place of business or is incorporated. A plaintiff’s venue 

choice is limited, but once a plaintiff meets its burden in selecting a proper forum, that forum 

choice should be respected. Only when a defendant satisfies its evidentiary burden to show with 

good cause that another acceptable venue is “clearly more convenient,” should a case be 

transferred. Here, Microsoft has simply not satisfied this burden. Microsoft has not shown that 

Austin is a “clearly more convenient” forum over Waco, and therefore, its motion should be 

denied. 

II. Background. 

Contrary to Microsoft’s arrogant and pejorative characterization of paSafeShare being a 

“non-practicing, patent-assertion entity” (D.I. 25 at 1),1 paSafeShare is a family-owned business 

that develops and markets software applications for securely distributing content. See Phadke 

Decl. at ¶4. In 2010, Dr. Madhav and Kedar Phadke founded paSafeShare to address deficiencies 

in existing content distribution security. While working together as technical consultants, the 

father-son duo noticed a significant oversight in content distribution safeguards. In particular, 

though there were various security techniques (e.g., password-protected documents, access 

restricted web portals) that could protect sensitive data in transit, they realized that there was no 

way to protect against a recipient’s unwanted distribution of the data. Id. at ¶5. 

In or around mid-2010, the paSafeShare team began developing innovative and 

proprietary content distribution technologies. paSafeShare’s technology led to the persistent 

1

 But to be clear, plaintiff has no objection to non-practicing entities. 

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protection of content distributed within and across firewalls. Id. at ¶6. Today, paSafeShare and 

its contract employees continue to maintain and update its software code and functionality at its 

office in Colts Neck, New Jersey. Id. at ¶8. And its patented technology is critical to the 

performance and security content distribution over networks, including Microsoft’s Azure 

Platform. 

III. Legal standard. 

“Section 1404(a) is intended to place discretion in the district court to adjudicate motions 

for transfer according to an ‘individualized, case-by-case consideration of convenience and 

fairness.’”2Stewart Org., Inc. v. Ricoh Corp., 487 U.S. 22, 29 (1988) (quoting Van Dusen v. 

Barrack, 376 U.S. 612, 622 (1964)). In determining whether a venue transfer is warranted 

pursuant to § 1404(a), “[t]he burden is on the movant to show good cause for the proposed 

transfer.” In re Volkswagen of America, Inc., 545 F.3d 304, 314 (5th Cir. 2008) (hereinafter 

“Volkswagen II”). The movant’s burden “reflects the appropriate deference to which the 

plaintiff’s choice of venue is entitled” and requires the movant to “clearly demonstrate” that the 

transfer is justified. Id. at 315. Accordingly, “when the transferee venue is not clearly more 

convenient than the venue chosen by the plaintiff, the plaintiff’s choice should be respected.”3

Id.4

2 Microsoft’s reference to an unrelated case, Exafer Ltd. v. Microsoft Corp., which involves, 

among other things, different parties, different patents, and different infringing activities, is a red 

herring and completely irrelevant to the case at hand. Each case must be considered on its own 

sets of facts and merit. Moreover, since the time when Exafer and Microsoft agreed to transfer 

their case from Waco to Austin, the process for assigning transferred cases has changed. 

3

 Unless indicated otherwise, all emphasis is added. 

4 In Volkswagen II, the Fifth Circuit explained that Congress tempered the effects of the §1391 

general venue statute by enacting the venue transfer statute. It explained that the underlying 

premise of § 1404(a) is that “courts should prevent plaintiffs from abusing their privilege under § 

1391 by subjecting defendants to venues that are inconvenient under the terms of §1404(a).” 545 

F.3d at 312-313. Volkswagen II was decided before TC Heartland. But after TC Heartland, a 

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The determination of convenience “turns on a number of public and private interest 

factors, none of which can be said to be of dispositive weight.” Action Indus., Inc. v. U.S. Fid. & 

Guar. Co., 358 F.3d 337, 340 (5th Cir. 2004). The private factors include: “(1) the relative ease 

of access to sources of proof; (2) the availability of compulsory process to secure the attendance 

of witnesses; (3) the cost of attendance for willing witnesses; and (4) all other practical problems 

that make trial of a case easy, expeditious and inexpensive.” In re Volkswagen AG, 371 F.3d 201, 

203 (5th Cir. 2004) (hereinafter “Volkswagen I”) (citing Piper Aircraft Co. v. Reyno, 454 U.S. 

235, 241 n.6 (1982)). The public factors include: “(1) the administrative difficulties flowing from 

court congestion; (2) the local interest in having localized interests decided at home; (3) the 

familiarity of the forum with the law that will govern the case; and (4) the avoidance of 

unnecessary problems of conflict of laws of the application of foreign law.” Id. Courts evaluate 

these factors based on “the situation which existed when suit was instituted.” Hoffman v. Blaski, 

363 U.S. 335, 343 (1960). 

IV. Argument. 

Microsoft does not dispute that venue is proper in the Waco Division of the Western 

District of Texas. Instead, the issue before the Court is whether Austin, Texas is a clearly more

convenient venue than Waco, Texas. Defendant contends that “the relative ease of access to 

sources of proof, the cost of attendance for willing witnesses, other practical issues, and Austin’s 

plaintiff/patentee’s choice of forum is limited under §1400(b); that is, §1400(b) is not a general 

venue statute of the type addressed in Volkswagen II. Plaintiff/patentees can sue only where a 

defendant has an established place of business or is incorporated. As such, paSafeShare submits 

that the deference due a plaintiff’s choice of forum should be fall somewhere between the 

Supreme Court’s decisions in Gilbert and Norwood, and be entitled to significant weight. In any 

event, at a minimum, paSafeShare’s choice of forum must be taken into account and should be 

respected. In re Volkswagen II, 545 F.3d at 314, n. 10. This is particularly true here, where 

Microsoft has utterly failed to establish good cause by meeting its significant burden and 

showing that the Austin Division is “clearly more convenient” than Waco. 

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local interest in deciding this case all strongly favor transfer.” D.I. 25 at 5. But Microsoft’s 

unsubstantiated and speculative claims of convenience fail to show “good cause” for an intradistrict transfer from Waco to Austin. Accordingly, the Court should deny Microsoft’s motion. 

A. The private interest factors weigh against transfer. 

1. The sources of proof are not more conveniently located in Austin. 

Microsoft must demonstrate that transfer will result in more convenient access to sources 

of proof. Fintiv, Inc. v. Apple Inc., 2019 U.S. Dist. LEXIS 171102, at *5 (W.D. Tex. Sep. 10, 

2019). In particular, this factor examines the location of the potential documents, records, and 

physical evidence relevant to the case. Durrett v. Walmart, Inc., 2018 U.S. Dist. LEXIS 186618, 

at *5 (E.D. Tex. Oct. 31, 2018). But by Microsoft’s own admission, “Microsoft’s engineering, 

sales, and financial documents relating to the Accused Products are primarily located in 

Redmond, Washington.” D.I. 25-1 at ¶6. 

Notably, Microsoft speculates that relevant Microsoft evidence could “potentially, in 

some instances,” be located in Austin. D.I. 25 at 5-6. Defendant cites to the declaration of 

Karishma Irani, an HR Manager at Microsoft, in support of this conjecture. Specifically, Ms. 

Irani states “the relevant business unit for these products in the US is EPD Engineering Team, 

which sits within the cloud and artificial intelligence organization, and is located in Redmond, 

Washington. The engineering organization responsible for the Accused Products is located in 

Redmond, Washington, and the engineers in this organization primarily work in Redmond. I am 

further aware that there are Microsoft employees who sit in the cloud and artificial intelligence 

organization in Austin, Texas, at least one of whom works on the Accused Products.” D.I. 25-1 

at ¶5. But Ms. Irani never addresses documentary evidence whatsoever, let alone the location 

and/or specific identification of relevant documents located in Austin. Indeed, given Microsoft’s 

own admission that “any relevant Microsoft evidence is located in Redmond,” (D.I. 25 at 5), 

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most, if not all, relevant documents are likely in Washington state. Accordingly, Microsoft 

cannot meet its evidentiary burden to show that this factor relating to sources of proof makes 

Austin a clearly more convenient forum over Waco. Further, Microsoft’s silence as to other 

sources of proof further weighs against transfer to Austin. 

In that regard, contrary to the lack of documents and evidence in Austin, paSafeShare’s 

investigation shows that there are likely documents and other evidence located in the Waco 

Division. Specifically, the ONLC Training Center in Waco, Texas is an authorized Microsoft 

Learning Partner that offers live and hands-on courses in Microsoft Azure as well as training in 

Azure Role-Based Certifications. Phadke Decl. at ¶13. The offered classes cover Azure content 

distribution technologies, including those implicated by the patents-in-suit. Id. at ¶14. ONLC’s 

Microsoft Azure Security Technologies course, for example, teaches students how to implement 

security controls, maintain security posture, and identify and remediate vulnerabilities by using a 

variety of Azure security tools. Id. The Waco ONLC Training Center is within the Court’s 

subpoena power, and Plaintiff intends to take discovery of the coursework relating to content 

distribution security on the Azure platform. This discovery is relevant to infringement and the 

value of paSafeShare’s patented technology. 

Additionally, Heart of Texas Network Consultants in Waco, Texas is a member of the 

Microsoft Partner Network. Id at ¶15. As such, Heart of Texas Network Consultants is certified 

to provide Microsoft’s Azure platform and the Microsoft Office 365 cloud-based productivity 

suite to businesses in Texas. Id. Heart of Texas Network Consultants is within the Court’s 

subpoena power, and Plaintiff intends to take discovery of resources relating to Azure’s content 

distribution technologies, which are relevant to the patents-in-suit. 

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Because Microsoft has failed to identify any sources of proof in Austin, this factor 

weighs against transfer. paSafeShare, on the other hand, has shown that there are likely relevant 

documents and witnesses located within the Waco Division – that too weighs against transfer. 

2. Microsoft fails to show that the cost of attendance for willing 

witnesses favors transfer. 

“The convenience of witnesses is the single most important factor in the transfer 

analysis.” Fintiv, 2019 U.S. Dist. LEXIS 171102, at *17. In order to prove this factor, “the party 

seeking the transfer must specify clearly . . . the key witnesses to be called and their location and 

must make a general statement of what their testimony will cover.” Silvertson v. Clinton, 2011 

U.S. Dist. LEXIS 104097, at *15 (N.D. Tex. Sept. 14, 2011) (citing 15 Charles A. Wright, et al., 

Federal Practice and Procedure § 3851, at 221-22 (3d ed. 2007)). Microsoft fails to do even that. 

Microsoft has neither identified any potential witnesses, much less any key witnesses it will call 

at trial, nor provided a general statement regarding their testimony.5 Instead, Microsoft argues 

that the cost of attendance for willing witnesses favors transfer because “it is possible that there 

are one or more potentially relevant witnesses in Austin.” D.I. 25 at 6.6 Yet again, Microsoft’s 

5

 Ms. Irani states that she is aware of at least one person who works on the accused products in 

Austin. D.I. 25-1 at ¶ 5. But that witness is unnamed. Moreover, Ms. Irani does not identify 

which accused product the person works on, and what that person does. It could very well be that 

this person’s job responsibilities are irrelevant to the patented technology at issue, even though 

that person may work on the Microsoft Azure platform, for example. At bottom, Ms. Irani’s 

vague statement about this single unidentified employee is not enough to satisfy Microsoft’s 

significant burden to show good cause for a transfer. 

6

 In Durrett v. Walmart, Inc., for example, the court refused to weigh this factor in favor of 

transfer even though “[m]ost, if not all, of the witnesses to the incident likely work or reside in 

[the transferee forum].” 2018 WL 5630521, at *9. As the court explained, “Defendant has named 

no [actual] witnesses, non-party or otherwise, to illustrate the inconvenience they would suffer if 

transfer was denied.” Id. Like in Durrett, Microsoft has not named any Austin employees who 

might serve as potential witnesses and consequently cannot sufficiently illustrate the 

inconvenience any particular witness would suffer if transfer is denied. 

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statements are highly speculative and unsubstantiated with evidence, and should thus be 

accorded no weight. 

Microsoft further argues “[f]or witnesses traveling from Redmond, Austin is more 

convenient because they can work out of Microsoft’s Austin facility.” D.I. 25 at 6. That 

assertion, however, is not compelling, and in fact, laughable. If any of the unnamed Microsoft 

witnesses are traveling from Redmond for a few days of trial, they will be focused on the trial, 

not working from the Austin office. Moreover, “[w]hile the Court must consider the convenience 

of both the party and non-party witnesses, it is the convenience of non-party witnesses that is the 

more important factor and is accorded greater weight in a transfer of venue analysis.” LBS 

Innovations, LLC v. Apple Inc., 2020 U.S. Dist. LEXIS 33064, at *15 (E.D. Tex. Feb. 26, 2020); 

see also Hammond Dev. Int'l, Inc. v. Google LLC, 2020 U.S. Dist. LEXIS 110984, at *11-12 

(W.D. Tex. June 24, 2020) (“The convenience of party witnesses is given little weight.”). Yet, 

Microsoft makes no attempt to analyze the cost of attendance for any third-party or paSafeShare 

witnesses. See Nat’l Cheng Kung Univ. v. Intel Corp., 2014 U.S. Dist. LEXIS 135683, at *5-6 

(E.D. Tex. Sep. 26, 2014) (denying Intel’s motion to transfer, and noting that Intel placed “heavy 

emphasis on its own witnesses without setting forth a thorough analysis of NKCU and thirdparty witnesses”). 

With regard to paSafeShare’s witnesses, this factor does not favor transfer. See Phadke 

Decl. at ¶12. As Mr. Phadke explains in his declaration, all of paSafeShare’s witnesses, including 

himself, his father, and patent prosecuting attorneys reside in New Jersey. There are flights to 

both Austin and Dallas from Newark Airport in New Jersey, and the witnesses could simply 

drive from Dallas to Waco for the trial. For the paSafeShare witnesses, traveling to Austin or 

traveling to Dallas, and then driving to Waco, is relatively the same in terms of convenience. But 

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there are more scheduling options and direct flights to Dallas, than Austin. And in this regard, 

the Court has recognized that it is just as easy for witnesses outside of Texas to fly to DFW and 

drive to Waco than it is for them to fly to Austin. See, e.g., RPB Safety, LLC v. Tru-Vision 

Plastics, Inc., 2019 U.S. Dist. LEXIS 233382, at *11 n.5 (W.D. Tex. Feb. 20, 2019) (“Waco is as 

accessible as Austin since the time to fly into Dallas and drive to Waco is relatively the same as 

flying into Austin since such flights usually make a connection in Dallas.”). 

Additionally, this Court has cited its own experience driving from Austin to Waco, noting 

that it “does not believe that the short hour and a half drive is as tiresome and burdensome as [the 

movant] contends.” Id. Moreover, on relative costs, this Court has determined that “[i]f anything, 

Waco would be cheaper for witnesses because of Austin’s high cost of living.” See id. at *10 

(“Regardless, ‘[w]hen travel over 100 miles could impose substantial expense on [] witness[es], 

the party that served the subpoena may pay that expense and the court can condition enforcement 

of the subpoena on such payment.’”). 

Moreover, as mentioned above, employees of the Waco ONLC Training Center and 

Heart of Texas Network Consultants are witnesses having intimate knowledge of Microsoft’s 

Azure platform and the accused products. These witnesses are within the Court’s subpoena 

power, and the lower cost of their attendance at trial weighs against transfer. Simply put, 

Microsoft has not met its burden to show that the location of witnesses and cost of witnesses to 

attend trial favor transfer. 

3. All other practical problems weigh against transfer. 

In considering a transfer, the court considers “all other practical problems that make trial 

of a case easy, expeditious and inexpensive.” Volkswagen II, 545 F.3d at 315. Microsoft asserts 

that this factor “strongly weighs in favor of transfer” because this case is in its early stage, and 

would not result in any meaningful delay. D.I. 25 at 7. But Microsoft fails to provide any 

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evidence indicating that having this case in Austin makes it easier, more expeditious, or less 

expensive than Waco. Ultimately, Microsoft’s argument rests on the fallacy that it is more 

convenient for this litigation to proceed in Austin – the very same dispute that Microsoft’s 

transfer motion raises. But it cannot be said that transferring this case to Austin would result in 

an easier and more expeditious resolution as compared to Waco. If this case were transferred to 

Waco, the assignment of this case and the case schedule will likely change, and therefore, this 

factor weighs against transfer. 

B. The public interest factors weigh against transfer. 

1. The local interest factor. 

This factor involves “the factual connection” that a case has with the transferor and 

transferee forum. Volkswagen I, 371 F.3d at 206. Microsoft asserts that Austin has a stronger 

local interest in this litigation because of Microsoft’s presence in the Austin Division. But 

Defendant’s generalized commercial presence is typically not sufficient to demonstrate any 

meaningful local interest in the outcome of a case. Found. Med., Inc. v. Guardant Health, Inc., 

2017 U.S. Dist. LEXIS 20431 at *10 (E.D. Tex. Feb. 14, 2017). In fact, the district court 

recognized that “it is generally a fiction that patent cases give rise to local controversy or 

interest, particularly without record evidence suggesting otherwise.” Id. 

Moreover, contrary to Microsoft’s assertions that Microsoft has no local Waco interests 

(D.I. 25 at 7), as explained above, Microsoft partners with the Waco ONLC Training Center and 

Heart of Texas Network Consultants to train employees and disseminate technologies implicated 

by the patents-in-suit. Retail stores located within the Waco Division, such as Best Buy, Office 

Depot, Walmart, and Target, also sell Microsoft Office 365, an accused product. Phadke Decl. at 

¶17. As such, Microsoft has a presence in Waco, and this Court has an interest in resolving it. 

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V. Conclusion. 

For the foregoing reasons, this Court should deny Microsoft’s motion to transfer this case 

to the Austin Division. 

Dated: September 25, 2020 Respectfully submitted, 

OF COUNSEL: /s/Raymond W. Mort, III 

Ronald M. Daignault (pro hac vice) 

Chandran B. Iyer (pro hac vice) 

Stephanie Mandir (pro hac vice) 

GOLDBERG SEGALLA LLP 

rdaignault@goldbergsegalla.com 

cbiyer@goldbergsegalla.com 

smandir@goldbergsegalla.com 

711 Third Avenue, Suite 1900 

New York, New York 10017 

Telephone: (646) 292-8700 

Raymond W. Mort, III 

Texas State Bar No. 00791308 

raymort@austinlaw.com 

THE MORT LAW FIRM, PLLC 

100 Congress Avenue, Suite 2000 

Austin, Texas 78701 

Tel/Fax: 512-865-7950 

Attorneys for Plaintiff paSafeShare LLC 

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