`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CARDIOCOM, LLC.
`
`Petitioner
`
`v.
`
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`
`Patent Owner
`
`CASE IPR: IPR2013-00451
`
`Patent No. 7,587,469
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`AFFIDAVIT OF BAS DE BLANK
`
`BOSCH 2001
`
`Cardiocom v Bosch
`
`IPR2013-00451
`
`
`
`Orrick Docket No.:
`
`|2833.2002.-'3
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`AFFIDAVIT 0F BAS DE BLANK
`
`l.
`
`I, Bas de Blank, am competent to present this affidavit, and have
`
`personal knowledge of the facts set forth herein.
`
`2.
`
`This affidavit is given in support of Patent Owner Robert Bosch
`
`Healthcare Systems, Inc.’s Motion for Pro Hac Vice Admission of Bas de Blank.
`
`3.
`
`I am a partner at the law firm of Orrick, Herrington & Sutcliffe.
`
`I am
`
`an experienced litigating attorney and have been a litigating attorney for more than
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`15 (fifteen) years.
`
`4.
`
`5.
`
`I have been litigating patent cases for over 15 (fifteen) years.
`
`I have litigated patent cases in the area of computerized information
`
`systems, the same subject matter as US. Patent No. 7,587,469, at issue in this inter
`
`partes review proceeding.
`
`6.
`
`I have an established familiarity with the subject matter at issue in this
`
`proceeding.
`
`I am counsel for Bosch in a co-pending district court litigation against
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`Petitioner Cardiocom, LLC (“Cardiocom”). That litigation is captioned Robert
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`Bosch Healthcare Systems, Inc. v. Cardiocom, LLC, Civil Action No. 2: l 3-cv-349
`
`(ED. Tex.) and involves US. Patent No. 7,587,469 also at issue in this interpartes
`
`review proceeding. As counsel for Bosch, I have been actively involved in preparing
`
`the technical aspects of the case relating to infi'ingement and validity of the ‘469
`
`
`
`OH'ick Docket No.: 1283320023
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`have an in-depth familiarity with the ‘469 Patent and its file history, as well as the
`
`references asserted as prior art by Cardiocom.
`
`I also have an in-depth familiarity
`
`with Bosch’s related US. Patent Nos. 7,516,192, 7,921,186, 7,870,249, and their file
`
`histories, which are also asserted in this co-pending litigation.
`
`7.
`
`I am also counsel for Bosch in a second co-pending district court
`
`litigation against Cardiocom. That litigation is captioned Robert Bosch Healthcare
`
`Systems, Inc. v. Cardiocom, LLC, Case No. 5:12-CV-3864-EJD (ND. Cal.) and
`
`involves U.S. Patent Nos. 6,368,273; 6,968,375; 7,252,636; and 8,140,663, which are
`
`related to the patent at issue, and US. Patent Nos. 7,941,327 and 8,015,025, which
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`involve similar computerized information systems technology as the ‘469 Patent.
`
`8.
`
`9.
`
`I am a member in good standing of the State Bar of California.
`
`I have never been suspended or disbarred from practice before any
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`court or administrative body.
`
`10. No court or administrative body has ever denied my application for
`
`admission to practice before it.
`
`11. No court or administrative body has ever imposed sanctions or
`
`contempt citations on me.
`
`12.
`
`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 the Code of
`
`Federal Regulations.
`
`
`
`On‘ick Docket No.: 1283320018
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`13.
`
`I understand that I will be subject to the USPTO Code of Professional
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`ReSponsibility set forth in 37 CPR. § ll.19(a).
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`14.
`
`I have not applied to appear pro hac vice in any other proceedings
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`before the Office in the last three (3) years.
`
`/Bas de Blank/
`
`Bas de Blank
`
`
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