Replies to post #94076 on UnifiedOnline Inc fka UOIP

[long uoip]

DECLARATION OF EARL HENNENHOEFER
COMMONWEALTH OF PENNSYLVANIA
) ss:
COUNTY OF CUMBERLAND
1. I, Earl Hennenhoefer, am one of three principals of CBV, Inc. ("CBV"), the
named plaintiff in the captioned lawsuit, with the two other principals being Richard Snyder and
Robert Stine. I submit this declaration in support of Plaintiff's Reply Brief in Further Support of
Its Application for Preliminary Injunction. I have personal knowledge of the facts submitted
herein, and will testify competently to them if called to do so.
2. I first learned of the contents and terms of the Advisory Services Agreement
between ChanBond, LLC and IPNAV, LLC in or around November of 2020 from Deirdre
Leane's lawsuit in the United States District Court for the Northern District of Texas, Leane et al
v. ChanBond LLC et al, C.A. No. 3:20-cv-03097 (N.D. Tex. Oct 09, 2020), seeking a temporary
restraining order against ChanBond LLC, among others.
3. I learned that Dierdre Leane, a Defendant in the above-captioned lawsuit, had her
attorney Mark Raskin draft an amendment to the PPA in the late summer of 2015 that would
remove CBV's reversion rights to the Patents under the PPA (the "PPA Amendment" dated August 27, 2015).
Upon information and belief, this followed Bentham (i.e., the litigation
financier in the Patent litigations that resulted in the Settlement Funds at issue in the above-
captioned case) indicating that it would be willing to finance a Patent lawsuit through trial in
hopes of obtaining a $300 million settlement. I was reluctant to execute this PPA Amendment,
but felt forced to sign the PPA Amendment by Ms. Leane, who otherwise threatened to take the
Patents to Europe so that CBV would not receive anything. This prior threat causes me current
concern that if Ms. Leane were to be distributed from the remaining
now, CBV would be unable to recover funds that it is due and owing under the PPA should the
funds be moved outside the United States.
4. I solemnly affirm under penalty of perjury pursuant to the laws of the United
States of America and the state of Delaware that the foregoing statements are true and correct.
Dated: April 7, 2022
Consnonwealth of Pennsylvania • Notary Seal
Stephen J. BIN, Notary Public
Cumberland County
My commission expires September 20, 2023