`_________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
`
`ZIMMER HOLDINGS, INC.
`ZIMMER, INC.
`Petitioners
`
`v.
`
`BONUTTI SKELETAL INNOVATIONS LLC
`Patent Owner
`
`Patent No. 7,837,736
`Filing Date: October 30, 2007
`Issue Date: November 23, 2010
`Title: MINIMALLY INVASIVE SURGICAL SYSTEMS AND METHODS
`
`__________________
`
`Inter Partes Review No. IPR2014-00191
`__________________
`
`DECLARATION OF KENNETH LIEBMAN IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
`
`Zimmer Holdings, Inc. and Zimmer, Inc.
`Exhibit 1011 - 1
`
`
`
`Inter Partes Review No. IPR2014-00191
`Declaration Of Kenneth Liebman In Support Of Motion For Pro Hac Vice Admission
`
`I, Ken Liebman, declare the following:
`
`1.
`
`I am a partner at the law firm of Faegre Baker Daniels LLP, in
`
`Minneapolis, Minnesota.
`
`2.
`
`I am a member in good standing of the Bar of Minnesota as well as
`
`the following Federal Courts:
`
`(a)
`
`Bar of California (11/29/79);
`
`(b) U.S. Court of Appeals for the Federal Circuit (9/3/93);
`
`(c)
`
`U.S. Court of Appeals for the Eleventh Circuit (9/19/91);
`
`(d) U.S. District Court for the Central District of California
`(1/15/80);
`
`(e)
`
`U. S. District Court for the Northern District of California
`(8/13/92); and
`
`(f)
`
`U.S. District Court for the District of Minnesota (11/5/93).
`
`My Minnesota Bar membership No. is 236731.
`
`I have never been suspended or disbarred from practice before any
`
`3.
`
`4.
`
`court or administrative body.
`
`5.
`
`I have never had a court or administrative body deny my application
`
`for admission to practice.
`
`6.
`
`I have never had any court impose sanctions or contempt citations
`
`against me.
`
`Zimmer Holdings, Inc. and Zimmer, Inc.
`Exhibit 1011 - 2
`
`
`
`Inter Partes Review No. IPR2014-00191
`Declaration Of Kenneth Liebman In Support Of Motion For Pro Hac Vice Admission
`
`7.
`
`I have read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials, as set forth in Part 42 of the
`
`C.F.R.
`
`8.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`Code of Professional Responsibility set forth in 37 C.F.R. §§ 10.20 et.seq. and
`
`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`9.
`
`In the past three years, I have applied for and been granted the right to
`
`appear pro hac vice in IPR2014-00321. I am concurrently applying to appear pro
`
`hac vice in IPR2014-00311. Both of the proceedings referred to in this paragraph
`
`relate to patents at issue in the litigation identified below in paragraph 11.
`
`10.
`
`I have been in private practice for over 33 years, and litigating patent
`
`cases for over 20 years. Several of these patent litigations involve USPTO post-
`
`grant procedures. For example, I currently represent Honeywell International, Inc.
`
`in an action pending before the United States District Court for the District of
`
`Minnesota, Honeywell International, Inc. v. Nest Labs, et al, No.0:12-cv-00299
`
`(SRN-JSM) (D. MN). The patents in suit in that action are the subject of inter
`
`partes reexamination requests: ‘958 Patent – 95/002,042, ‘948 Patent – 95/002,037,
`
`790 Patent – 95/002,043, ‘789 Patent – 95/002,039, ‘504 Patent – 95/002,041, ‘899
`
`Patent – 95/002,040, ‘988 Patent – 95/002,038. I have litigated other cases
`
`involving related reexamination proceedings as well.
`
`Zimmer Holdings, Inc. and Zimmer, Inc.
`Exhibit 1011 - 3
`
`
`
`Inter Partes Review No. IPR2014-00191
`Declaration Of Kenneth Liebman In Support Of Motion For Pro Hac Vice Admission
`
`11.
`
`I am familiar with the subject matter at issue in this proceeding. I am
`
`lead counsel for Petitioner in the matter Bonutti Skeletal Innovation LLC v. Zimmer
`
`Holdings Inc. et al., No.1:12-cv-1107-GMS (filed on Sept. 10, 2012), which is
`
`related to and involves the same patent at issue in this proceeding.
`
`12.
`
`I hereby declare that all statements 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 are made with the knowledge that willful false
`
`and the like are punishable by fine, imprisonment, or both, under section 1001 of
`
`Title 18 of the United States Code.
`
`February ___, 2014
`
`Respectfully Submitted,
`
`______________________________
`Kenneth Liebman
`FAEGRE BAKER DANIELS LLP
`2200 Wells Fargo Center
`90 S. 7th Street
`Ken.liebman@FaegreBD.com
`Telephone: (612) 766-8800
`Fax: (612) 766-1600
`
`dms.us.53722967.01
`
`Zimmer Holdings, Inc. and Zimmer, Inc.
`Exhibit 1011 - 4
`
`
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