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`Filed on behalf of: Black Hills Media, LLC
`By:
`Theodosios Thomas
`Black Hills Media, LLC
`5400 Trinity Rd. Suite 303
`Raleigh, NC 27607
`Tel: (919) 233-1942, Ext. 203
`Fax: (919) 233-9907
`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`YAMAHA CORPORATION OF AMERICA
`Petitioner
`
`v.
`
`BLACK HILLS MEDIA, LLC
`Patent Owner
`___________________
`
`Case No. IPR2013-00598
`U.S. Patent 8,214,873
`___________________
`
`Declaration of Lana Gladstein In Support of
` Motion For Admission Pro Hac Vice
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`I, Lana Gladstein, declare as follows:
`
`IPR2013-00598
`U.S. Patent 8,214,873
`
`1.
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`I am an attorney licensed to practice law in the state of Massachusetts,
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`and am a registered patent attorney before the United States Patent
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`and Trademark Office (Reg. No. 48,502). I am also admitted to
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`practice before the U.S. District Court for the District of
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`Massachusetts and the Court of Appeals for the Federal Circuit. I am
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`a member in good standing in all jurisdictions where I have been
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`admitted to practice.
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`2.
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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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`3.
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`I have never had an application denied for admission before any court
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`or administrative body.
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`4.
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`I have never had any sanctions or contempt citations imposed by any
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`court or administrative body.
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`5.
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`I have read and agree to 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
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`of the C.F.R.
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`6.
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`I affirm my agreement as a registered practitioner before the USPTO
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`to be subject to the USPTO Rules of Professional Conduct 37 C.F.R.
`
`2
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`
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`IPR2013-00598
`U.S. Patent 8,214,873
`§§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. §
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`11.19(a).
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`7.
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`I am a registered USPTO practitioner. I have not, however, applied to
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`appear pro hac vice in any other proceedings before the USPTO in the
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`last three (3) years.
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`8.
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`I have been a partner at the law firm of Pepper Hamilton LLP since
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`2011, and an associate at Pepper Hamilton (2008-2010), Goodwin
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`Procter LLP (2002-2008), and at Nixon Peabody (2000-2002). I have
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`extensive experience in patent law and have been involved in patent
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`prosecution and patent litigation for the past 13 years, including in
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`post-grant proceedings such as interferences.
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`9.
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`I am familiar with the subject matter at issue in this proceeding. As a
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`registered practitioner before the USPTO, I have been engaged by the
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`Patent Owner to represent the Patent Owner before the Board in this
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`proceeding. I have undertaken the study of inter alia the ‘873 Patent,
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`the Petition for Inter Partes Review, and the art cited in the Petition. I
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`am also familiar with the co-pending litigations filed by the Patent
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`Owner and identified by the Petitioner in the Petition for Inter Partes
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`Review (pp. 2-4), in which the ‘873 Patent was asserted against the
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`Petitioner and others in various jurisdictions. I have acquired a
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`3
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`
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`IPR2013-00598
`U.S. Patent 8,214,873
`substantial understanding of the underlying legal and technological
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`issues at stake in the these proceedings.
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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
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`be true; and further that these statements are made with the knowledge that
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`willful false statements and the like so made are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code and that such willful false statements may jeopardize the validity of
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`U.S. Patent No. 8,214,873.
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`Dated: December 18, 2013
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`
`
` /Lana Gladstein/
`Lana Gladstein, Reg. No. 48,502
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02210
`Tel: (617) 204-5100
`Fax: (617) 204-5150
`
`4
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`
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`IPR2013-00598
`U.S. Patent 8,214,873
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`CERTIFICATE OF SERVICE
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`
`
`
`dfehrman@mofo.com
`marjomand@mofo.com
`
`
`
` I
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`
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` hereby certify that on December 18, 2013, a true and accurate copy of this paper,
`DECLARATION OF LANA GLADSTEIN IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
`ADMISSION, was served on the following counsel for Petitioner Yamaha of America via email
`and U.S. Express Mail:
`
`David L. Fehrman
`Mehran Arjomand
`Morrison & Foerster LLP
`707 Wilshire Boulevard
`Los Angeles, CA 90017-3543
`Tel: (213) 892-5630
`Fax: (323) 210-1329
`
`
`Dated:
`
` December 18, 2013
`
`
`
`By: /Theodosios Thomas R45159/
`Theodosios Thomas, Reg. No. 45,159
`Black Hills Media, LLC
`5400 Trinity Rd. Suite 303
`Raleigh, NC 27607
`Tel: (919) 233-1942, Ext. 203
`Fax: (919) 233-9907
`Attorney for Patent Owner
`
`
`