Filed on behalf of Patent Owner Network-l Security Solutions, Inc.
`
`By: Robert G. Mukai, Esq.
`BUCHANAN INGERSOLL & RODNEY PC
`
`1737 King Street, Suite 500
`Alexandria, Virginia 22314—2727
`Telephone (703) 836—6620
`Facsimile (703) 8362021
`robert.mukai@bipc.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`AVAYA INC.
`
`Petitioner
`
`V.
`
`NETWORK—1 SECURITY SOLUTIONS, INC.
`Patent Owner
`
`Patent 6,218,930
`Administrative Patent Judges Jameson Lee, Joni Y. Chang and Justin T. Arbes
`
`Case IPR2013-00071
`
`DECLARATION OF MR. GREG DOVEL
`IN SUPPORT OF MOTION FOR PRO HAC VICE ADMISSION
`
`
`
`By: Robert G. Mukai, Esq.
`BUCHANAN INGERSOLL & RODNEY PC
`
`1737 King Street, Suite 500
`Alexandria, Virginia 22314—2727
`Telephone (703) 836—6620
`Facsimile (703) 8362021
`robert.mukai@bipc.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`AVAYA INC.
`
`Petitioner
`
`V.
`
`NETWORK—1 SECURITY SOLUTIONS, INC.
`Patent Owner
`
`Patent 6,218,930
`Administrative Patent Judges Jameson Lee, Joni Y. Chang and Justin T. Arbes
`
`Case IPR2013-00071
`
`DECLARATION OF MR. GREG DOVEL
`IN SUPPORT OF MOTION FOR PRO HAC VICE ADMISSION
`
`
`
`Case No. IPR2013-0007l
`
`US. Patent No. 6,218,930
`Declaration of Greg Dovel, Esq.
`
`1, Greg Dovel, declare as follows:
`
`Counsel is an exgerienced litigating attorney
`
`1.
`
`I am co—founder of Dovel & Luner and am head of the firm’s trial
`
`practice.
`
`I have been a litigation attorney for 24 years — since 1988.
`
`l
`
`have represented a wide range of clients in business litigation matters
`
`and have focused on patent litigation since 2000. I first-chaired
`
`numerous jury and bench trials to verdict.
`
`I graduated Harvard Law
`
`School (JD. 1986, Magna Cum Laude), and then served as law clerk
`
`to Ninth Circuit Judge J. Clifford Wallace. I then clerked for Chief
`
`Justice Warren E. Burger and Associate Justice Antonin Scalia of the
`
`United States Supreme Court. I was a litigation associate and then
`
`partner at Kaye, Scholer, Fierman, Hayes & Handler in Los Angeles,
`
`before leaving to form my own firm in 1995.
`
`2.
`
`I have been primarily litigating patent cases since 2000.
`
`I have been
`
`lead counsel on over 30 patent cases.
`
`I litigated a number of them
`
`through trial and have conducted oral arguments on 6 patent cases
`
`before the Federal Circuit.
`
`
`
`Case No. IPR2013-00071
`
`US. Patent No. 6,218,930
`Declaration of Greg Dovel, Esq.
`
`Familiarity with the subz'ect matter at issue in the proceeding (US. Patent
`
`62189302:
`
`5.
`
`I am familiar with the subject matter at issue in this proceeding,
`
`specifically the U.S. Patent 6,218,930 (the “‘930 Patent”). My
`
`familiarity with the ‘930 Patent is based on the following.
`
`I am lead counsel in the following litigation in which the ‘930 Patent
`
`is asserted against various manufactures of Power-Over—Ethernet
`
`equipment: Network-1 Security Solutions, Inc. v. AlcateZ—Lucent USA
`
`Inc, Case No. 6:11 cv 492 (“Alcatel Litigation”). The Alcatel
`
`Litigation has been pending in the United States District Court for the
`
`Eastern District of Texas Tyler Division since September 201 1.
`
`In addition, I was lead counsel in the following litigation in which the
`
`‘930 Patent was also asserted against various manufacturers of Power—
`
`Over—Ethernet equipment: Network—I Security Solutions, Inc. v.
`
`CiscovSystems, Inc. (“Cisco Litigation”). The Cisco Litigation was
`
`pending in the United States District Court for the Eastern District of
`
`Texas Tyler Division from February 2008 through July 2010. My
`
`work on the Cisco Litigation included:
`
`
`
`Case No. IPR2013—00071
`
`US. Patent No. 6,218,930
`Declaration of Greg Dovel, Esq.
`
`(a)
`
`conducting the Markman hearing in which the claim terms of
`
`the ‘930 Patent were construed;
`
`(b)
`
`deposing the Defendant’s technical expert relating to the
`
`validity of the ‘930 Patent; and
`
`(c)
`
`trying the Cisco Litigation to a jury, including opening
`
`statement, direct examination of Network—1 ’s technical expert
`
`and cross-examination of the Defendants’ technical expert.
`
`The Cisco litigation settled after the fouith day ofjury trial.
`
`General Requirements
`
`8.
`
`I am a member in good standing of the Bar of the State of California
`
`and am admitted to practice before the United States Supreme Court,
`
`United States Courts of Appeals for the Ninth Circuit and the Federal
`
`Circuit, and six federal District Courts.
`
`9.
`
`I have never been suspended, disbarred, sanctioned or cited for
`
`contempt by any court or administrative body.
`
`10.
`
`I have never had a court or administrative body deny my application
`
`for admission to practice.
`
`
`
`Case No. IPR2013-00071
`
`US. Patent No. 6,218,930
`Declaration of Greg Dovel, Esq.
`
`11.
`
`I have never had sanctions or contempt citations imposed on me by
`
`any court or administrative body.
`
`12.
`
`I have read and will comply with Office Patent Trial Practice Guide
`
`and the Board’s Rules of Practice for Trials, as set forth in Part 42 of
`
`the C.F.R. § § 10.20 et seq. and disciplinary jurisdiction under 37
`C.F.R. § 1119(3).
`.
`
`13.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`Code of Professional Responsibility set forth in 37 C.F.R. § § 10.20 at
`
`seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`14.
`
`In the past three (3) years, I have not appeared pro hac vice in any
`
`proceedings before the United States Patent and Trademark Office.
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to
`
`be true; and further that these statements are made with the knowledge that
`
`willful false statements and the like so made are punishable by fine or
`
`imprisonment, or both, under Section 1001 of Title 18 of the United States
`
`Code and that such willful false statements may jeopardize the validity of
`
`US. Patent No. 6,218,930.
`
`
`
`Case No. IPR2013—00071
`
`US. Patent No. 6,218,930
`Declaration of Greg Dovel, Esq.
`
`Date: January/4; 2012
`
`Dovel & Luner LLP
`
`201 Santa Monica Boulevard,
`
`Suite 600
`
`Santa Monica, CA 90401
`(310) 656-7066
`
`
`
`Case No. IPR2013-0007l
`
`US. Patent No. 6,218,930
`
`Declaration of Greg Dovel, Esq.
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that a true and correct copy of the foregoing
`
`DECLARATION OF MR. GREG DOVEL IN SUPPORT OF MOTION PRO
`
`HAC VICE PURSUANT TO 37 C.F.R. 42.10 is being served upon the following
`3'
`this 25th day of January 2012, via EXPRESS MAIL:
`
`Jeffrey D. Sanok
`Jonathan Lindsay
`CROWELL & MORING LLP
`
`Intellectual Property Group
`1001 Pennsylvania Avenue, NW.
`Washington, DC 20004—2595
`
`and electronically via e—mail: AVl -PRPS@Crowell.com
`
`Date: January 25, 201:;
`
`”7"
`
`W4 , M’
`
`Robert G. Mukai, Esq.
`Registration No. 28,531
`Counselfor NETWORK—I SECURITY
`SOLUTIONS, INC.
`
`
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