`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CARDIOCOM, LLC
`
`Petitioner
`
`V.
`
`ROBERT BOSCH I-[EALTHCARE SYSTEMS, INC.
`
`Patent Owner
`
`CASE IPR: IPR2013-OO468
`
`Patent No. 7,516,192
`
`AFFIDAVIT OF SIDDHARTHA VENKATESAN
`
`BOSCH 2006
`
`
`
`Orrick Docket No.: 128332003
`
`1.
`
`I, Siddhartha Venkatesan, 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 Siddhartha
`
`Venkatesan.
`
`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
`
`nine years.
`
`4.
`
`5.
`
`I have been litigating patent cases for over nine years.
`
`I have litigated patent cases in the area of computerized information
`
`systems, the same subject matter as US. Patent No. 7,516,192, 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 US. Patent No. 7,516,192 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
`
`‘ 192 Patent, including detailed analysis of the ‘ 192 Patent and its file history. As
`
`
`
`Orrick Docket No.: 12833.2003
`
`such, I have an in-depth familiarity with the ‘ 192 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. 7,840,420, 7,921,186, 7,870,249,
`
`and their file histories, which are also asserted in this co-pending litigation.
`
`7.
`
`I am a member in good standing of the State Bar of California and
`
`New York.
`
`8.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`9.
`
`No court or administrative body has ever denied my application for
`
`admission to practice before it.
`
`10. No court or administrative body has ever imposed sanctions or
`
`contempt citations on me.
`
`11.
`
`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.
`
`12.
`
`I understand that 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).
`
`
`
`Orrick Docket No.: 128332003
`
`13.
`
`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:
`
`
`
`IPR2013-00468
`
`
`
`
`
`
`
`14.
`
`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 18 U.S.C. 1001, and may jeopardize the validity of the application or any
`
`patent issuing thereon.
`
`Dated: February 28, 2014 Siddhartha Venkat
`
`