DECLARATION OF KARL RUPP IN SUPPORT OF IKORONGO’S 

OPPOSITION TO LYFT’S MOTION TO TRANSFER

Page 1

UNITED STATES DISTRICT COURT

WESTERN DISTRICT OF TEXAS

WACO DIVISION

IKORONGO TECHNOLOGY LLC )

and IKORONGO TEXAS LLC, ) 

)

Plaintiffs, )

) Civil Action No. 6:20-cv-00258-ADA

v. )

)

LYFT, INC. )

)

Defendants. ) 

DECLARATION OF KARL RUPP IN SUPPORT OF IKORONGO’S OPPOSITION TO 

LYFT’S MOTION TO TRANSFER

I, Karl Rupp, declare as follows:

1. I am an attorney of record for Plaintiffs Ikorongo Texas LLC and Ikorongo Technology LLC in 

these actions, and I am admitted to practice before this Court. If called to testify, I would and 

could competently testify to the following facts within my personal knowledge, except as to 

matters stated on information and belief, as to which matters, I could testify that I believe them 

to be true.

2. To compare the cost of attending trial for witnesses, I looked up flights from each locality where 

witnesses are located to Austin-Bergstrom International Airport (AUS), Dallas/Fort Worth 

International Airport(DFW), and San Francisco International Airport (SFO). Except for 

witnesses traveling from Seattle or Korea, travel is less expensive and requires less time when 

traveling to AUS or DFW. For travel that is more expensive to Texas than to San Francisco, the 

cost difference is less than $100. A single night’s stay in a hotel in Waco instead of San Francisco 

would more than make up for this cost difference.

3. The following paragraphs reflect information gathered by using Google to look up flight times 

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DECLARATION OF KARL RUPP IN SUPPORT OF IKORONGO’S 

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and prices between various locations relevant in this action. All the prices in the following 

paragraphs are for round-trip flights between the stated airports. The stated times are each way.

4. I looked up flight times from the San Francisco International Airport (SFO) to Austin-Bergstrom 

International Airport (AUS). I found there were direct flights of 3 hours and 30 minutes of travel 

time, starting at $219. I also looked up flights from San Jose (SJC) to Austin-Bergstrom 

International Airport (AUS). I found there were direct flights of 3 hours and 30 minutes, starting 

at $304. I also looked up flights from SFO to Dallas/Fort Worth International Airport (DFW). I 

found there were direct flights of 3 hours and 30 minutes, starting at $247. I also looked up 

flights from SJC to DFW. I found there were direct flights of 3 hours and 34 minutes, starting 

at $267. See Exhibit H.

5. I looked up flight times from the John F. Kennedy International Airport (JFK) to AUS. I found 

there were direct flights of 4 hours and 2 minutes of travel time, starting at $327. I also looked 

up flights from JFK to DFW. I found there were direct flights of 4 hours and 2 minutes, starting 

at $103. I also looked up flights from LGA to DFW. I found there were direct flights of 3 hours 

and 39 minutes, starting at $60. See Exhibit H.

6. I looked up flight times from Incheon International Airport (ICN) in Korea to AUS. I found 

flights of 15 hours and 37 minutes travel time for $696. See Exhibit H.

7. I looked up flight times from Seattle-Tacoma International Aiport (SEA) to AUS. I found there 

were direct flights of 4 hours travel time starting at $218. I looked up flights from SEA to DFW. 

I found there were direct flights of 3 hours and 55 minutes travel time starting at $289. I looked 

up flights from SEA to SFO. I found direct flights of 2 hours and 8 minutes travel time starting 

at $175. See Exhibit H.

8. I looked up flights from Raleigh-Durham International Airport (RDU) to AUS. I found there 

were direct flights of 3 hours and 26 minutes travel time starting at $197. I looked up flights 

from RDU to DFW. I found there were direct flights of 3 hours and 25 minutes travel time

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DECLARATION OF KARL RUPP IN SUPPORT OF IKORONGO’S 

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starting at $343. I looked up flights from RDU to SFO. I found direct flights of 5 hours and 46 

minutes travel time starting at $219. See Exhibit H.

9. I looked up flights from Denver International Airport (DEN) to DFW. I found there were direct 

flights of 1 hour and 55 minutes travel time starting at $56. I looked up flights from DEN to 

AUS. I found there were direct flights of 2 hours and 9 minutes travel time starting at $80. I 

looked up flights from DEN to SFO. I found there were direct flights of about 2 hours and 52 

minutes travel time starting at $67. See Exhibit H.

10. I looked up flights from Nashville International Airport (BNA) to SFO. I found direct flights of 

4 hours and 50 minutes starting at $359. I looked up flights from BNA to DFW. I found direct 

flights of 2 hours and 18 minutes starting at $201. I looked up flights from BNA to AUS. I 

found direct flights of 2 hours starting at $113. See Exhibit H.

11. I looked up flights from Newark Liberty International Airport (EWR) to SFO. I found direct 

flights of 6 hours and 13 minutes starting at $289. I looked up flights from EWR to DFW. I 

found direct flights of 3 hours and 42 minutes starting at $103. I looked up flights from EWR to 

AUS. I found direct flights of 3 hours and 48 minutes starting at $105. See Exhibit H.

12. I looked up flights from Hartsfield-Jackson Atlanta International Airport (ATL) to SFO. I found 

direct flights of 5 hours and 22 minutes starting at $221. I looked up flights from ATL to DFW. 

I found direct flights of 2 hours and 28 minutes starting at $60. I looked up flights from ATL to 

AUS. I found direct flights of 2 hours and 9 minutes starting at $82. See Exhibit H.

13. I had a paralegal e-mail hotels near the federal courthouses in Waco and San Francisco to inquire 

about the pricing of conference rooms to be used by counsel during trial, from January 24, 

2022 to January 28, 2022. I received the following price quotes: The Hilton Waco offered 

a conference room for $750 for 5 days. The Phoenix Hotel in San Francisco offered a studio 

suite that can be used as a conference room for $409 per night, or $2,045 for 5 days. See

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DECLARATION OF KARL RUPP IN SUPPORT OF IKORONGO’S 

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Exhibit I.

14. Mr. Reed lives in Denver, Colorado and Mr. Briggs lives in Nashville, TN.

15. True and correct copies of the following documents are attached as exhibits hereto:

Exhibit A Assignments of Patent Rights

Exhibit B Assignment of Patent Rights from members to Ikorongo TX

Exhibit C Julia Riessen Deposition Transcript 

Exhibit D Austin Business Journal Article “Google confirms Austin expansion, 

will begin moving in next year,” found at:

https://www.bizjournals.com/austin/news/2019/06/14/googleconfirms-austin-expansion-will-begin-moving.html

Exhibit E New York Times article: “They Got Rich Off Uber and Lyft. Then 

They Moved to Low-Tax States” found at: https://nyti.ms/2H8odAU

Exhibit F Daniel Hochman Speaker Profile, QConPlus, found at:

https://plus.qconferences.com/plus2020/speakers/daniel-hochman

Exhibit G Lyft Revenue Usage Statistics (2020) – Business of Apps, found at: 

https://www.businessofapps.com/data/lyft-statistics/

Exhibit H Screenshots of research regarding travel costs from various localities 

to SFO, AUS, and DFW

Exhibit I Correspondence from The Hilton Waco and The Phoenix Hotel in 

San Francisco regarding the cost of conference rooms

I declare under penalty of perjury of the laws of the United States of America and Texas, that 

the foregoing is true and correct. Executed on the date noted below in Dallas, Texas. 

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DECLARATION OF KARL RUPP IN SUPPORT OF IKORONGO’S 

OPPOSITION TO LYFT’S MOTION TO TRANSFER

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Dated: January 5, 2020 Respectfully submitted,

/s/ Karl Rupp________________________

KARL RUPP

State Bar No. 24035243

NIX PATTERSON, LLP

Advancial Building

1845 Woodall Rodgers Freeway, Suite 1050

Dallas, Texas 75201

972.831.1188 - Telephone

972.444.0716 - Facsimile

krupp@nixlaw.com

DEREK GILLILAND

State Bar No. 24007239

SOREY, GILLILAND & HULL, LLP

P.O. BOX 4203

109 W. Tyler Street

Longview, Texas 75601

903.212.2822 - Telephone

903.212.2864 - Telephone

derek@soreylaw.com

HOWARD WISNIA

WISNIA PC

12770 High Bluff Drive, Suite 200

San Diego, California 92130

858.461.0989

howard@wisnialaw.com

COUNSEL FOR PLAINTIFFS

CERTIFICATE OF SERVICE

I hereby certify that on January 5, 2020, I electronically filed the foregoing with the Clerk 

of using the CM/ECF system which will send notification of such filing to all counsel of record. 

/s/ Karl Rupp_______________________ 

KARL RUPP

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