`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CARDIOCOM LLC
`
`Petitioner
`
`V.
`
`ROBERT BOSCH HEALTHCARE SYSTEMS, INC.
`
`Patent Owner
`
`Case IPR2013—0045 1
`
`Patent 7,587,469
`
`Mailed: November 26, 20.13
`
`DECLARATION OF WILLIAM D. SCHULTZ IN SUPPORT OF
`
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE
`
`CARDIOCOM EX. 1011
`
`CARDIOCOM EX. 1011
`
`
`
`Case [PR2013—00451
`
`Patent 7, 587, 469
`
`In support of the Motion for Admission Pro Hac Vice, I, 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
`
`CPR.
`
`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.
`
`§ 11.19(a).
`
`
`
`Case [PR2013—00451
`
`Patent 7,587,469
`
`7.
`
`I am applying concurrently to appear pro hac vice before the US. Patent
`
`and Trademark Office in the following proceedings before the Office:
`
`IPR2013—0043 1;
`
`IPR2013-00439;
`
`IPR2013-00449;
`
`IPR2013-00460;
`
`IPR2013-00468; 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
`
`(ED. TeX., filed Apr. 26, 2013), which involves the following US.
`
`patents:
`
`7,5 1 6,192;
`
`7,587,469;
`
`7,769,605;
`
`7,840,420;
`
`7,870,249; and
`
`7,921,186.
`
`
`
`Case IPR2013—00451
`
`Patent 7, 58 7, 469
`
`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,
`
`v
`
`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 (N.D. Cal, filed July 24, 2012),
`
`which involves the following US. patents:
`
`6,368,273;
`
`6,968,375;
`
`7,252,636;
`
`7,941,327;
`
`8,015,025; and
`
`8,140,663.
`
`
`
`Case IPR2013—00451
`
`Patent 7, 58 7, 469
`
`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.
`
`My, 26, 201;
`
`%;6/
`
`Date
`
`William D. Schultz
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
