`
`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: IPR2013-00449
`Patent No. 7,840,420
`_____________________
`
`AFFIDAVIT OF LILLIAN MAO
`
`OHSUSA:754609544.2
`
`Page 1 of 5
`
`BOSCH 2008
`Cardiocom v Bosch
`IPR2013-00449
`
`
`
`Orrick Docket No.: 12833.2007
`
`1.
`
`I, Lillian Mao, 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 Lillian Mao.
`
`3.
`
`I am an associate at the law firm of Orrick, Herrington & Sutcliffe. I
`
`am an experienced litigating attorney and have been a litigating attorney for more
`
`than 3 (three) years.
`
`4.
`
`5.
`
`I have been litigating patent cases for over 3 (three) years.
`
`I have litigated patent cases in the area of computerized information
`
`systems, the same subject matter as U.S. Patent No. 7,840,420, 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 Petitioner Cardiocom, LLC (“Cardiocom”). That litigation is captioned
`
`Robert Bosch Healthcare Systems, Inc. v. Cardiocom, LLC, Civil Action No. 2:13-
`
`cv-349 (E.D. Tex.) and involves U.S. Patent No. 7,840,420 also at issue in this
`
`inter partes review proceeding. As counsel for Bosch, I have been actively
`
`involved in preparing the technical aspects of the case relating to infringement and
`
`validity of the ‘420 Patent, including detailed analysis of the ‘420 Patent and its
`
`file history. As such, I have an in-depth familiarity with the ‘420 Patent and its file
`
`OHSUSA:754609544.2
`
`Page 2 of 5
`
`
`
`Orrick Docket No.: 12833.2007
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`history, as well as the references asserted as prior art by Cardiocom. I also have an
`
`in-depth familiarity with Bosch’s related U.S. Patent No. 7,769,605, and its file
`
`history, which is 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 (N.D. Cal.) and
`
`involves U.S. Patent Nos. 6,368,273; 6,968,375; 7,252,636; 7,941,327; 8,015,025;
`
`and 8,140,663, which involve similar computerized information systems
`
`technology as the ‘420 Patent.
`
`8.
`
`I am a member in good standing of the State Bar of California.
`
`9. I have never been suspended or disbarred from practice before any
`
`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 Section 37
`
`of the Code of Federal Regulations.
`
`OHSUSA:754609544.2
`
`Page 3 of 5
`
`
`
`Orrick Docket No.: 12833.2007
`
`13. I understand that I will be subject to the USPTO Rules of
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`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
`
`jurisdiction under 37 C.F.R. § 11.19(a).
`
`14. I have not applied to appear pro hac vice in any other proceedings
`
`before the Office in the last three (3) years. I am concurrently applying to appear
`
`pro hac vice before the Office in the following inter partes review proceedings:
`
`Proceeding
`
`IPR2013-00431
`
`IPR2013-00439
`
`IPR2013-00449
`
`IPR2013-00451
`
`IPR2013-00460
`
`IPR2013-00468
`
`IPR2013-00469
`
`U.S. Patent No.
`
`7,921,186
`
`7,769,605
`
`7,840,420
`
`7,587,469
`
`7,870,249
`
`7,516,192
`
`7,516,192
`
`15. 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
`
`OHSUSA:754609544.2
`
`Page 4 of 5
`
`
`
`Orrick Docket No.: 12833.2007
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`or imprisonment or both, under 18 U.S.C. 1001, and may jeopardize the validity
`
`of the application or any patent issuing thereon.
`
`/Lillian Mao/
`Lillian Mao
`
`OHSUSA:754609544.2
`
`Page 5 of 5
`
`
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