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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`CARDIOCOM LLC
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`Petitioner
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`V.
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`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
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`Patent Owner
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`Case IPR2013—0045 1
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`Patent 7,587,469
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`Mailed: November 26, 20.13
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`DECLARATION OF WILLIAM D. SCHULTZ IN SUPPORT OF
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`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE
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`CARDIOCOM EX. 1011
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`CARDIOCOM EX. 1011
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`
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`Case [PR2013—00451
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`Patent 7, 587, 469
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`In support of the Motion for Admission Pro Hac Vice, I, William D. Schultz,
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`do declare and state as follows:
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`1.
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`I am a member in good standing of the Bars of: Minnesota, the United
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`States District Court for the Western District of Wisconsin, the United
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`States Court of Appeals for the Seventh Circuit, the United States Court
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`of Appeals for the Eighth Circuit, and the United States District Court for
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`the District of Minnesota.
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`2.
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`I have no suspensions or disbarments from practice before any court or
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`administrative body.
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`3.
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`I have never had any court or administrative body deny my application to
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`practice before said court or administrative body.
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`4.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
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`5.
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`I have read and will comply with the Office Patent Trial Practice Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of 37
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`CPR.
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`6.
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`I will be subject to the USPTO Rules of Professional Conduct set forth in
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`37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R.
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`§ 11.19(a).
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`
`
`Case [PR2013—00451
`
`Patent 7,587,469
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`7.
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`I am applying concurrently to appear pro hac vice before the US. Patent
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`and Trademark Office in the following proceedings before the Office:
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`IPR2013—0043 1;
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`IPR2013-00439;
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`IPR2013-00449;
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`IPR2013-00460;
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`IPR2013-00468; and
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`IPR2013-00469.
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`8.
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`9.
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`I have been a litigating attorney for more than eleven years.
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`I have been litigating patent cases for at least eleven years.
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`10.
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`I am second counsel in the case Robert Bosch Healthcare Systems, Inc. v.
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`Cardiocom, LLC, and Abbott Diabetes Care, Inc. , No. 2: 13-CV-349
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`(ED. TeX., filed Apr. 26, 2013), which involves the following US.
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`patents:
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`7,5 1 6,192;
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`7,587,469;
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`7,769,605;
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`7,840,420;
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`7,870,249; and
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`7,921,186.
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`
`
`Case IPR2013—00451
`
`Patent 7, 58 7, 469
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`ll.
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`I have worked extensively with the expert retained for the litigation
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`identified above and in this proceeding. I have also reviewed the expert’s
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`report regarding the invalidity of the patent at issue in this proceeding. I
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`have also worked extensively in developing invalidity positions for the
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`patent at issue in this proceeding. Developing invalidity positions
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`required, for instance, a thorough understanding of the prior art,
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`v
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`including the prior art cited in the instant case, as well as a thorough
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`understanding of the patent at issue.
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`12.
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`I am second counsel in the case Robert Bosch Healthcare Systems, Inc. v.
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`Cardiocom, LLC, No. 12—cv-3864 EJD (N.D. Cal, filed July 24, 2012),
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`which involves the following US. patents:
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`6,368,273;
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`6,968,375;
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`7,252,636;
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`7,941,327;
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`8,015,025; and
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`8,140,663.
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`
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`Case IPR2013—00451
`
`Patent 7, 58 7, 469
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`I hereby declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true,
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`and further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`My, 26, 201;
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`%;6/
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`Date
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`William D. Schultz
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`