`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CARDIOCOM LLC
`
`Petitioner
`
`V.
`
`ROBERT BOSCH I-IEALTHCARE SYSTEMS, INC.
`
`Patent Owner
`
`Case IPR2013-00439
`
`Patent 7,769,605
`
`Mailed: November 26, 2013
`
`DECLARATION OF WILLIAM D. SCHULTZ IN SUPPORT OF
`
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE
`
`CARDIOCOM EX. 101 7
`
`CARDIOCOM EX. 1017
`
`
`
`Case IPR2013-00439
`
`Patent 7, 769, 605
`
`In support of the Motion for Admission Pro Hac Vice, 1, William D. Schultz,
`
`do declare and state as follows:
`
`1.
`
`I am a member in good standing of the Bars of: Minnesota, the United
`
`States District Court for the Western District of Wisconsin, the United
`
`States Court of Appeals for the Seventh Circuit, the United States Court
`
`of Appeals for the Eighth Circuit, and the United States District Court for
`
`the District of Minnesota.
`
`2.
`
`I have no suspensions or disbarments from practice before any court or
`
`administrative body.
`
`3.
`
`I have never had any court or administrative body deny my application to
`
`practice before said court or administrative body.
`
`4.
`
`I have never been sanctioned or cited for contempt by any court or
`
`administrative body.
`
`5.
`
`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 of 37
`
`C.F.R.
`
`6.
`
`I will be subject to the USPTO Rules of Professional Conduct set forth in
`
`37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R.
`
`§ll.l9(a).
`
`
`
`Case IPR2013-00439
`
`Patent 7, 769,605
`
`7.
`
`I am applying concurrently to appear pro hac vice before the U.S. Patent
`
`and Trademark Office in the following proceedings before the Office:
`
`IPR2013-00431;
`
`IPR20 l 3-00449;
`
`IPR2013-00451;
`
`IPR20l3—O0460;
`
`IPR20l3—0O468; and
`
`IPR2013-00469.
`
`8.
`
`9.
`
`I have been a litigating attorney for more than eleven years.
`
`I have been litigating patent cases for at least eleven years.
`
`10.
`
`I am second counsel in the case Robert Bosch Healthcare Systems, Inc. v.
`
`Cardiocom, LLC, and Abbott Diabetes Care, Inc. , No. 2: 13-CV—349
`
`(E.D. Tex., filed Apr. 26, 2013), which involves the following U.S.
`
`patents:
`
`7,5 16,192;
`
`7,587,469;
`
`7,769,605;
`
`7,840,420;
`
`7,870,249; and
`
`7,921,186.
`
`
`
`Case IPR2013-00439
`
`Patent 7, 769, 605
`
`ll.
`
`I have worked extensively with the expert retained for the litigation
`
`identified above and in this proceeding. I have also reviewed the expert’s
`
`report regarding the invalidity of the patent at issue in this proceeding. I
`
`have also worked extensively in developing invalidity positions for the
`
`patent at issue in this proceeding. Developing invalidity positions
`
`required, for instance, a thorough understanding of the prior art,
`
`including the prior art cited in the instant case, as well as a thorough
`
`understanding of the patent at issue.
`
`12.
`
`I am second counsel in the case Robert Bosch Healthcare Systems, Inc. v.
`
`Cardiocom, LLC, No. 12-cv-3864 EJD G\I.D. Cal., filed July 24, 2012),
`
`which involves the following U.S. patents:
`
`6,368,273;
`
`6,968,375;
`
`7,252,636;
`
`7,941 ,3 27;
`
`8,015,025; and
`
`8,140,663.
`
`
`
`Case IPR20]3-00439
`
`Patent 7, 769,605
`
`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 were 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.
`
`Mav. 26,2012
`
`l
`
`A
`
`Date
`
`William D. Schultz
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