In Agbogwe v. State, 414 S.W.3d 820, 838 (Tex.App. -- Houston 1st Dist. 2013, no pet.), the court was faced with a similar argument that defense counsel was ineffective for failing to request an instruction directing the jury to disregard certain evidence. The appellant made "no argument" to explain how the evidence was admissible for one purpose but not for another, and thereby failed to demonstrate that a limiting instruction would have been required by Rule 105 if requested. Id. at 838-39. Therefore, Appellant did not meet "his burden of demonstrating, by a preponderance of the evidence, that defense counsel rendered ineffective assistance when he failed to request a limiting instruction." Id. at 839.