We have carried out a survey of long 50ks XMM-Newton observations of a sample of bright , variable AGN . We found a distinctive energy dependence of the variability in RXJ0136.9-3510 where the fractional variability increases from 0.3 to 2 keV , and then remains constant . This is in sharp contrast to other AGN where the X-ray variability is either flat or falling with energy , sometimes with a peak at \sim 2 keV superimposed on the overall trend . Intriguingly these unusual characteristics of the variability are shared by one other AGN , namely RE J1034+396 , which is so far unique showing a significant X-ray QPO . In addition the broad band spectrum of RXJ0136.9-3510 is also remarkably similar to that of RE J1034+396 , being dominated by a huge soft excess in the EUV-soft X-ray bandpass . The bolometric luminosity of RX J0136.9-3510 gives an Eddington ratio of about 2.7 for a black hole mass ( from the H beta line width ) of 7.9 \times 10 ^ { 7 } M _ { \sun } . This mass is about a factor of 50 higher than that of RE J1034+396 , making any QPO undetectable in this length of observation . Nonetheless , its X-ray spectral and variability similarities suggest that RE J1034+396 is simply the closest representative of a new class of AGN spectra , representing the most extreme mass accretion rates .