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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`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
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`v.
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`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)
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`
`
`
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`FILED VIA PRPS
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`
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`
`
`Case IPR2014-00281
`Patent 6,324,463
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`
`
`
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` Declaration of Chi Cheung Supporting
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` Jaguar Land Rover North America, LLC’s
`Motion for Pro Hac Vice
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`
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`I, Chi Cheung, resident of New York City, NY declare as follows:
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`1.
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`I am an attorney at the firm of Latham & Watkins LLP, counsel of
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`record for Co-Petitioner Jaguar Land Rover North America, LLC. I have personal
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`knowledge of the facts set forth in this declaration and, if called as a witness, could
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`and would testify competently under oath.
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`2.
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`I am a member in good standing of the State Bar of New York
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`(Admitted July 7, 2009, Registration No. 4740205) and am also admitted to
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`practice before the U.S. District Courts for the Southern District of New York,
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`Eastern District of New York, Eastern District of Michigan and the U.S. Court of
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`Appeals for the Federal Circuit.
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`3.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body. No application of mine for admission to practice
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`before any court or administrative body has ever been denied. No court or
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`administrative body has imposed sanctions or contempt citations against me.
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`4.
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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 C.F.R.
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`I acknowledge and agree that I will be subject to the USPTO Rules of Professional
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`Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under
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`
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`2
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`
`
`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).
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`5.
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`I have an undergraduate degree in Systems Design Engineering from
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`the University of Waterloo and graduated from Northwestern University School of
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`Law in 2008. I have four years of electrical hardware and computer software work
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`experience from working as an engineering intern during my time at Waterloo, and
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`as a full-time engineer afterwards.
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`6.
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`I have over six years of patent litigation experience. I am a member of
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`Latham & Watkins intellectual property group, with a focus on patent litigation. In
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`2014, I was named a “Rising Star” by Super Lawyers magazine in the area of
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`intellectual property litigation.
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`7.
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`I have been actively involved in the related district court litigation
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`between the Patent Owner and Co-Petitioner JLR, Cruise Control Technologies
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`LLC v. Jaguar Land Rover North America LLC, 2:14-cv-11511 (E.D. Mich.) prior
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`to it being stayed. I was admitted to E.D. Mich. for the primary purpose of
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`litigating that matter on May 29, 2014. The ‘463 Patent, which is at issue in this
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`proceeding, is the sole patent asserted by the Patent Owner in the district court
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`litigation.
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`8.
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`I have been actively involved in analyzing and assisting with the
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`Petition for Inter Partes Review submitted in this proceeding, including
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`3
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`Case IPR2014—OO28 ll
`Patent 6,324,463
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`.4
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`4
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`* Declaration of Chi Cheung Supporting
`a
`Jaguar Land Rover North America, LLC’s
`Motion for Pro Hac Vice
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`4
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`Petitioner’s factual
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`investigation and development of its invalidity and claim
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`construction positions regarding the claims of U.S. PatentNo. 6,324,463 (the “‘463
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`Patent”).
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`I drafted much of the Petitionfor Inter Partes TR6ViCW of the ‘463 Patent
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`in this proceeding.
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`6
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`9. g
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`I worked closely;with Lead Counsel for each of four related petitions
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`submitted in the following four proceedings.1(“Re1ated IPR Proceedings”)
`involving the same patent (the ‘463 Patent) that are currently pending before the
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`Patent Trialand Appeal Board:
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`0 Case No. IPR2014—0O289;
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`0 Case No. IPR20l4—0O291;
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`4
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`C-6 CaseNo;IPR2014—0O279;l
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`L - Case No. IPR2014—0O280.
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`Co—Petitioner JLR is also a co—petitioner in each of these RelatedIPR Proceedings.
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`10.
`Irhave not applied to appear pro hac vice in any other proceeding
`before the USPTO}
`A
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`Executedon March ll,’20l5 in New York City; NY.
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`
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`Chi Cheung
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`
`
`Case IPR2014-00281
`Patent 6,324,463
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`
`
`
`
` Declaration of Chi Cheung Supporting
`
` Jaguar Land Rover North America, LLC’s
`Motion for Pro Hac Vice
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`
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`CERTIFICATE OF SERVICE
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`I certify that on this 11th day of March, 2015, a copy of:
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`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)
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`was served by mail on Patent Owner’s lead and backup counsel, at the following
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`addresses:
`
`John Kasha
`Kelly L. Kasha
`Kasha Law LLC
`14532 Dufief Mill Road
`North Potomac, MD 20878
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`5
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`Respectfully submitted,
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`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