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`UNITED STATES PATENT AND TRADEMARK OFFICE
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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 IPR: IPR2013-00468
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`Patent No. 7,516,192
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`AFFIDAVIT OF BAS DE BLANK
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`BOSCH 2001
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`Cardiocom v Bosch
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`IPR20l3-00468
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`OI-lSUSA:75458l073.l
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`Page I 0f4
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`‘H
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`0n'ick Docket No.: 128332002.-"SB
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`AFFIDAVIT OF BAS DE BLANK
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`1.
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`I, Bas de Blank, am competent to present this affidavit, and have
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`personal knowledge of the facts set forth herein.
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`2.
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`This affidavit is given in support of Patent Owner Robert Bosch
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`Healthcare Systems, Inc.’s Motion for Pro Hac Vice Admission of Bas de Blank.
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`3.
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`I am a partner at the law firm of Orrick, Herrington & Sutcliffe. I am
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`an experienced litigating attorney and have been a litigating attorney for more than
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`15 (fifteen) years.
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`4.
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`I have been litigating patent cases for over 15 (fifteen) years.
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`5.
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`I have litigated patent cases in the area of computerized information
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`systems, the same subject matter as U.S. Patent No. 7,516,192, at issue in this inter
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`partes review proceeding.
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`6.
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`I have an established familiarity with the subject matter at issue in this
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`proceeding.
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`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: 13-cv-349
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`(E.D. Tex.) and involves U.S. Patent No. 7,516,192 also at issue in this inter partes
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`review proceeding. As counsel for Bosch, I have been actively involved in preparing
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`the technical aspects of the case relating to infringement and validity of the ‘I92
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`Patent, including detailed analysis of the ‘192 Patent and its file history. As such, I
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`OI-ISUSA:75458l0'l'J.l
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`Page 2 of4
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`Orrick Docket No.:
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`l2833.2002."5B
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`have an in-depth familiarity with the ‘ 192 Patent and its file history, as well as the
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`references asserted as prior art by Cardiocom.
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`I also have an in-depth familiarity
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`with Bosch’s related U.S. Patent Nos. 7,921,186, 7,587,469, 7,870,249, and their file
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`histories, which are also asserted in this co-pending litigation.
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`7.
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`I am also counsel for Bosch in a second co-pending district court
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`litigation against Cardiocom. That litigation is captioned Robert Bosch Healthcare
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`Systems, Inc. v. Cardiocom, LLC, Case No. 5:12-CV—3864-EJD (N.D. Cal.) and
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`involves U.S. Patent Nos. 6,368,273; 6,968,375; 7,252,636; and 8,140,663, which are
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`related to the patent at issue, and U.S. Patent Nos. 7,941,327 and 8,015,025, which
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`involve similar computerized information systems technology as the ‘l92 Patent.
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`8.
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`9.
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`I am a member in good standing of the State Bar of California.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
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`10. No court or administrative body has ever denied my application for
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`admission to practice before it.
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`1 1. No court or administrative body has ever imposed sanctions or
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`contempt citations on me.
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`12.
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`I have read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of the Code of
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`Federal Regulations.
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`OHSUSA:75-lS8l0'i'3.l
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`Page 3 0f4
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`Onick Docket No.:
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`|2833.'.Z002f5B
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`13.
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`I understand that I will be subject to the USPTO Code of Professional
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`Responsibility set forth in 37 C.F.R. § l1.l9(a).
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`14.
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`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.
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`/Bas de Blank!
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`Bas de Blank
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`OHSUSA:754S8 l{l73.l
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