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`I, Jonathan R. DeFosse, declare as follows:
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`1.
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`I am a member in good standing of the Bar of Virginia and the Bar of
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`the District of Columbia, as well as the following Federal Courts:
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`United States District Court for the District of Columbia;
`United States District Court for the Eastern District of Virginia;
`United States Court of Appeals for the Fourth Circuit;
`United States Court of Appeals for the Eleventh Circuit;
`United States Court of Appeals for the Federal Circuit.
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`2.
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`I have not been suspended or disbarred from practice before any court
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`or administrative body.
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`3.
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`I have never been denied admission to practice before any court or
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`administrative body.
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`4.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
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`5.
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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 of37 C.P.R.
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`6.
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`I will be subject to the USPTO Rules of Professional Conduct set
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`forth in 37 C.P.R.§§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.P.R.§
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`11.19(a).
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`7.
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`I have not applied to appear pro hac vice before the Office in the last
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`three (3) years, although I am simultaneously applying to appear pro hac vice in
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`1
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`IPR2014-00647 - Ex. 1016
`Mercedes-Benz USA LLC, Petitioner
`American Vehicular Sciences LLC, Patent Owner
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`the following inter partes review proceedings: IPR2014-00643, IPR2014-00644,
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`IPR2014-00645, and IPR2014-00646.
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`8.
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`I have an established familiarity with the subject matter at issue in the
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`proceeding, because I am representing Petitioner as a defendant in the related
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`proceeding American Vehicular Sciences LLC v. Mercedes-Benz U.S. Int 'I, Inc.,
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`No.6: 13-cv-00308 (B.D. Tex.). In this related proceeding, Patent Owner has
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`asserted U.S. Patent No. 5,845,000 against Petitioner. My experience representing
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`Petitioner in this related proceeding, concerning the same patent against the same
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`Patent Owner, provides me with an established familiarity with the subject matter
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`at issue in the current proceeding.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Dated: June 3, 20 14
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`o athan R. DeFosse
`earman & Sterling LLP
`01 Pennsylvania Avenue, NW, Ste. 900
`Washington, D.C. 20004
`Telephone: (202) 508-8000
`Facsimile: (202) 508-8100
`Jonathan.defosse@shearman.com
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`2
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