`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________________
`
`
`CONOPCO, INC. d/b/a UNILEVER
`Petitioner
`
`v.
`
`THE PROCTER & GAMBLE COMPANY
`Patent Owner
`
`_________________________
`
`
`Case IPR2014-00507
`Patent 6,451,300
`
`_________________________
`
`
`AFFIDAVIT IN SUPPORT OF PATENT OWNER’S MOTION FOR
`PRO HAC VICE ADMISSION OF THOMAS R. GOOTS
`PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`
`
`Case IPR2014-00507
`Patent 6,451,300
`I, Thomas R. Goots, am more than twenty-one years of age, am
`
`1.
`
`competent to present this affidavit, and have personal knowledge of the facts set
`
`forth herein.
`
`2.
`
`This affidavit is given in support of the Patent Owner The Procter &
`
`Gamble Company’s Motion for Pro Hac Vice Admission.
`
`3.
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`4.
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`I am a Partner at the law firm of Jones Day.
`
`I have been a patent litigation attorney for nearly 19 years, and I have
`
`been litigating patent cases during that entire time period. I have litigated at least
`
`25 patent infringement actions, including at least 7 involving chemical
`
`compositions, including matters for P&G.
`
`5.
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`I am a member in good standing of the State Bar of Ohio. I have
`
`never been suspended or disbarred from practice before any court or
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`administrative body.
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`6.
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`I have never been ultimately denied admission to practice before
`
`any court or administrative body.
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`7. No court or administrative body has ever imposed sanctions or
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`contempt citations on me.
`
`8.
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`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.
`
`1
`
`
`
`Case IPR2014-00507
`Patent 6,451,300
`I understand that I will be subject to the USPTO Rules of Professional
`
`9.
`
`Conduct set forth in 37 C.F.R §§ 11.101 et seq. and disciplinary jurisdiction under
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`37 C.F.R. § 11.19(a).
`
`10.
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`I am concurrently seeking pro hac vice admission to appear in Patent
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`Owner’s co-pending related matters, Cases IPR2013-00505, IPR2014-00506,
`
`and IPR2013-00509.
`
`11.
`
`I have an established familiarity with the subject matter at issue in
`
`this proceeding. I have read and understand the pleadings submitted by
`
`Petitioner and Patent Owner in this proceeding and in Cases IPR2013-00505,
`
`IPR2014-00506, and IPR2013-00509. I have engaged in hours of strategic and
`
`substantive discussions regarding this proceeding with David M. Maiorana, who
`
`is the lead counsel for Patent Owner in this proceeding and in Cases IPR2013-
`
`00505, IPR2014-00506, and IPR2013-00509. Through my nearly 19 years of
`
`patent litigation experience, I am very familiar with the legal theories advanced
`
`in this case.
`
`12.
`
`I have reviewed in detail U.S. Patent No. 6,451,300 (“the ’300
`
`patent”), which is the patent challenged in this proceeding. I have also reviewed
`
`Exhibits submitted by Petitioner in this proceeding. I am also counsel of record
`
`in litigation involving the ’300 patent before the United States District Court for
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`the Southern District of Ohio (Civil Action No. 1:13-cv-732-TSB).
`
`2
`
`
`
`Case IPR20 14-00507
`Patent 6,451,300
`I understand that IPR counsel for Petitioner has agreed not to oppose
`
`13.
`
`Patent Owner's motion for my pro hac vice admission in this proceeding.
`
`Jltw&RkdJ
`
`Thomas R. Goots
`
`Sworn to and subscribed before me this 2ih day of June, 2014.
`
`3
`
`
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