throbber
UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`TOYOTA MOTOR NORTH AMERICA, INC., SUBARU OF AMERICA, INC.,
`AMERICAN HONDA MOTOR CO., INC., NISSAN NORTH AMERICA, INC.,
`FORD MOTOR COMPANY, JAGUAR LAND ROVER NORTH AMERICA,
`LLC, AND VOLVO CARS OF NORTH AMERICA, LLC
`
`Petitioner
`
`v.
`
`CRUISE CONTROL TECHNOLOGIES LLC
`Patent Owner
`
`_______________
`
`Case IPR2014-00281
`U.S. Patent 6,324,463
`
`_______________
`
`
`DECLARATION OF CHI CHEUNG IN SUPPORT OF
`CO-PETITIONER JAGUAR LAND ROVER NORTH AMERICA, LLC’S
`MOTION FOR PRO HAC VICE ADMISSION UNDER 37 C.F.R. § 42.10(c)
`
`
`
`
`
`FILED VIA PRPS
`
`
`
`
`
`
`

`
`Case IPR2014-00281
`Patent 6,324,463
`
`
`
`
`
` Declaration of Chi Cheung Supporting
`
` Jaguar Land Rover North America, LLC’s
`Motion for Pro Hac Vice
`
`
`
`I, Chi Cheung, resident of New York City, NY declare as follows:
`
`1.
`
`I am an attorney at the firm of Latham & Watkins LLP, counsel of
`
`record for Co-Petitioner Jaguar Land Rover North America, LLC. I have personal
`
`knowledge of the facts set forth in this declaration and, if called as a witness, could
`
`and would testify competently under oath.
`
`2.
`
`I am a member in good standing of the State Bar of New York
`
`(Admitted July 7, 2009, Registration No. 4740205) and am also admitted to
`
`practice before the U.S. District Courts for the Southern District of New York,
`
`Eastern District of New York, Eastern District of Michigan and the U.S. Court of
`
`Appeals for the Federal Circuit.
`
`3.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body. No application of mine for admission to practice
`
`before any court or administrative body has ever been denied. No court or
`
`administrative body has imposed sanctions or contempt citations against me.
`
`4.
`
`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 the C.F.R.
`
`I acknowledge and agree 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
`
`
`
`2
`
`

`
`Case IPR2014-00281
`Patent 6,324,463
`
`
`
`
`
` Declaration of Chi Cheung Supporting
`
` Jaguar Land Rover North America, LLC’s
`Motion for Pro Hac Vice
`
`
`37 C.F.R. § 11.19(a).
`
`5.
`
`I have an undergraduate degree in Systems Design Engineering from
`
`the University of Waterloo and graduated from Northwestern University School of
`
`Law in 2008. I have four years of electrical hardware and computer software work
`
`experience from working as an engineering intern during my time at Waterloo, and
`
`as a full-time engineer afterwards.
`
`6.
`
`I have over six years of patent litigation experience. I am a member of
`
`Latham & Watkins intellectual property group, with a focus on patent litigation. In
`
`2014, I was named a “Rising Star” by Super Lawyers magazine in the area of
`
`intellectual property litigation.
`
`7.
`
`I have been actively involved in the related district court litigation
`
`between the Patent Owner and Co-Petitioner JLR, Cruise Control Technologies
`
`LLC v. Jaguar Land Rover North America LLC, 2:14-cv-11511 (E.D. Mich.) prior
`
`to it being stayed. I was admitted to E.D. Mich. for the primary purpose of
`
`litigating that matter on May 29, 2014. The ‘463 Patent, which is at issue in this
`
`proceeding, is the sole patent asserted by the Patent Owner in the district court
`
`litigation.
`
`8.
`
`I have been actively involved in analyzing and assisting with the
`
`Petition for Inter Partes Review submitted in this proceeding, including
`
`
`
`3
`
`

`
`Case IPR2014—OO28 ll
`Patent 6,324,463
`«
`.4
`«
`t
`
`4
`
`4
`
`4
`
`4
`
`3
`
`:
`4;
`
`6
`
`* Declaration of Chi Cheung Supporting
`a
`Jaguar Land Rover North America, LLC’s
`Motion for Pro Hac Vice
`
`4
`
`Petitioner’s factual
`
`investigation and development of its invalidity and claim
`
`construction positions regarding the claims of U.S. PatentNo. 6,324,463 (the “‘463
`
`Patent”).
`
`I drafted much of the Petitionfor Inter Partes TR6ViCW of the ‘463 Patent
`
`in this proceeding.
`
`6
`
`9. g
`
`I worked closely;with Lead Counsel for each of four related petitions
`
`submitted in the following four proceedings.1(“Re1ated IPR Proceedings”)
`involving the same patent (the ‘463 Patent) that are currently pending before the
`
`Patent Trialand Appeal Board:
`
`0 Case No. IPR2014—0O289;
`
`0 Case No. IPR20l4—0O291;
`
`4
`
`C-6 CaseNo;IPR2014—0O279;l
`
`L - Case No. IPR2014—0O280.
`
`Co—Petitioner JLR is also a co—petitioner in each of these RelatedIPR Proceedings.
`
`10.
`Irhave not applied to appear pro hac vice in any other proceeding
`before the USPTO}
`A
`
`Executedon March ll,’20l5 in New York City; NY.
`
`
`
`Chi Cheung
`
`

`
`Case IPR2014-00281
`Patent 6,324,463
`
`
`
`
`
` Declaration of Chi Cheung Supporting
`
` Jaguar Land Rover North America, LLC’s
`Motion for Pro Hac Vice
`
`
`
`CERTIFICATE OF SERVICE
`
`
`I certify that on this 11th day of March, 2015, a copy of:
`
`DECLARATION OF CHI CHEUNG IN SUPPORT OF
`CO-PETITIONER JAGUAR LAND ROVER NORTH AMERICA, LLC’S
`MOTION FOR PRO HAC VICE ADMISSION UNDER 37 C.F.R. § 42.10(c)
`
`was served by mail on Patent Owner’s lead and backup counsel, at the following
`
`addresses:
`
`John Kasha
`Kelly L. Kasha
`Kasha Law LLC
`14532 Dufief Mill Road
`North Potomac, MD 20878
`
`
`
`5
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`ERISE IP, P.A
`
`BY: /s/ Eric Buresh
`Eric A. Buresh, Reg. No. 50,394
`Jason R. Mudd, Reg. No. 57,700
`6201 College Blvd., Suite 300
`Overland Park, KS 66211
`P: (913) 777-5600
`F: (913) 777-5601
`eric.buresh@eriseip.com
`jason.mudd@eriseip.com
`
`ATTORNEYS FOR PETITIONERS

This document is available on Docket Alarm but you must sign up to view it.


Or .

Accessing this document will incur an additional charge of $.

After purchase, you can access this document again without charge.

Accept $ Charge
throbber

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.

throbber

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.

Become a Member

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

We are redirecting you
to a mobile optimized page.





Document Unreadable or Corrupt

Refresh this Document
Go to the Docket

We are unable to display this document.

Refresh this Document
Go to the Docket