`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`AMERICAN EXPRESS COMPANY, EXPEDIA, INC., ORBITZ WORLDWIDE,
`INC., PRICELINE.COM, INC., TRA VELOCITY.COM LP, and YAHOO! INC.
`Petitioners
`
`V.
`
`HARVEY LUNENFELD
`Patent Owner
`
`Case CBM20 14-00001
`Patent 8,326,924
`
`AFFIDAVIT IN SUPPORT OF MOTION
`FOR PRO HAC VICE ADMISSION OF
`J. CHRISTOPHER CARRAWAY UNDER 37 C.F.R. § 42.10(c)
`
`Petitioners
`Exhibit No. 1019
`American Express et al. v. Luenfeld
`CBM2014-00001
`
`
`
`CBM20 14-0000 l
`Patent 8,326,924
`
`I, J. Christopher Carraway, declare that:
`
`1.
`
`I am a partner at the law firm ofKiarquist Sparkman, LLP, and
`
`provide this declaration in support of Petitioners' Motion for Pro Hac Vice
`
`Admission. I have personal knowledge of the matters set forth below, and if called
`
`as a witness, I could and would testify competently to these matters.
`
`2.
`
`I have over 17 years of patent litigation experience, including fact and
`
`expert discovery, Markman hearings, and oral arguments in patent infringement
`
`matters before both Federal district courts and the United States Court of Appeals
`
`for the Federal Circuit. Most of my work as a patent litigation attorney has been in
`
`the technical areas of computer software, computer hardware, and e-commerce.
`
`3.
`
`Prior to beginning practice in patent litigation, I served as a law clerk
`
`to The Honorable William C. Bryson of the United States Court of Appeals for the
`
`Federal Circuit in 1995-96.
`
`4.
`
`I am a member in good standing ofthe State Bars of Oregon,
`
`Colorado (inactive), Washington, and Montana. I have never been suspended or
`
`disbarred from practice before any court or administrative body.
`
`5.
`
`No court or administrative body has ever denied my application for
`
`admission to practice before it.
`
`6.
`
`No court or administrative body has ever imposed sanctions or
`
`contempt citations on me.
`
`AFFIDAVIT OF
`J. CHRISTOPHER CARRAWAY
`
`Page 1
`
`
`
`CBM20 14-00001
`Patent 8,326,924
`
`7.
`
`I have read and will comply with the Office Patent Trial Practice
`
`Guide and the Board's Rules of Practice for Trials set forth in part 42 of37 C.F.R.
`
`8.
`
`I understand that I will be subject to the Office's Rules of Professional
`
`Conduct set forth in 3 7 C. F .R. § § 11.1 0 1 et seq. and disciplinary jurisdiction under
`
`37 C.F.R. § ll.l9(a).
`
`9.
`
`I am concurrently seeking pro hac vice admission to appear in
`
`Petitioners' co-pending related matter against Patent Owner, Case CBM20 14-
`
`00050, challenging claims of U.S. Patent No. 8,239,451, which is in the same
`
`patent family as the patent at issue in this proceeding. I have not applied to appear
`
`pro hac vice in any other proceeding before the Office in the last three (3) years.
`
`10.
`
`I have established familiarity with the subject matter at issue in this
`
`proceeding. I served as Petitioners' counsel in the parallel litigations in the U.S.
`
`District Court for the District of Delaware in which the same patent was at issue:
`
`Metasearch Systems, LLC v. Expedia, Inc. et al., 12-cv-1188-LPS (D. Del.);
`
`Metasearch Systems, LLC v. Travelocity.com LP, 12-cv-1189-LPS (D. Del.);
`
`Metasearch Systems, LLC v. Orbitz Worldwide, Inc., 12-cv-1190-LPS (D. Del.);
`
`Metasearch Systems, LLC v. Priceiine.com Inc., 12-cv-1191-LPS (D. Del.);
`
`Metasearch Systems, LLC v. Yahoo! Inc., 12-cv-1223-LPS (D. Del.);
`
`AFFIDAVIT OF
`J. CHRISTOPHER CARRAWAY
`
`Page 2
`
`
`
`CBM20 14-0000 1
`Patent 8,326,924
`
`Metasearch Systems, LLC v. American Express Co. eta!., 12-cv-1225-LPS (D.
`
`Del.). These litigations are now stayed pending the outcome of this proceeding
`
`and Case CBM20 14-00050.
`
`11. Therefore, I have an established familiarity with the subject matter at
`
`issue in this proceeding.
`
`Pursuant to 18 U.S.C. § 1001, I declare under penalty of perjury that the
`
`foregoing is true and correct.
`
`J.
`
`Sworn to and subscribed before me
`this _:7_ day of March, 2014.
`
`Notary Public
`
`[
`
`0
`
`'
`
`.•''~GI'lA_; '',
`SAM GILMER
`"' 1::1~
`~1> ',
`No <try Publ•c
`0 o~o'TAR1-1£ , for the St<:~to of Montana
`1 ~ *: SF-:A-l : *:
`Ros.drng at:
`-0#: Bozeman, Montana
`-
`":.\Sl;.
`c
`~ "9h:
`. ~ ........
`',/t::·C:;:'w.o~ --- My ommisSion Exprres:
`January 15, 2016
`'''''"''''''
`
`AFFIDAVIT OF
`J. CHRISTOPHER CARRAWAY
`
`Page 3
`
`
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