`
`Patent No. 6,896,773
`IPR2014-00726
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`THE GILLETTE COMPANY, TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY, LTD., TSMC NORTH AMERICA
`CORPORATION, FUJITSU SEMICONDUCTOR LIMITED, and FUJITSU
`SEMICONDUCTOR AMERICA, INC.,
`Petitioners
`
`v.
`
`ZOND, LLC
`Patent Owner
`
`_____________________
`
`Inter Partes Review Case No. IPR2014-007261
`
`Patent 6,896,773 B2
`
`_____________________
`
`
` AFFIDAVIT OF TIGRAN VARDANIAN IN SUPPORT OF PATENT
`OWNER’S MOTION FOR PRO HAC VICE ADMISSION
`
`
`
`I, Tigran Vardanian, being duly sworn and upon oath, hereby attest to
`
`the following:
`
`i.
`
`I am a member in good standing of the New York and Illinois Bars,
`
`as well as the following Federal Courts:
`
`
`1 Case IPR 2014-01481 has been joined with the instant proceeding.
`
`1
`
`ZOND 2002
`
`
`
`
`
`Patent No. 6,896,773
`IPR2014-00726
`
`a) U.S. District Court for the Northern District of Illinois; and
`
`b) U.S. District Court for the Eastern District of Michigan.
`
`ii.
`
`I have not been suspended or disbarred from practice before any court
`
`or administrative body.
`
`iii.
`
`I have never had an application for admission to practice before any
`
`court or administrative body denied.
`
`iv. No sanction or contempt citation has been imposed against me by any
`
`court or administrative body.
`
`v.
`
`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 Code of Federal Regulations.
`
`vi.
`
`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 37 C.F.R. § 11.19(a).
`
`vii. Other than presently applying to appear Pro Hac Vice before the
`
`Office in connection with the Inter Partes Review proceedings of the
`
`patents listed below in section ix, I have not applied to appear Pro
`
`Hac Vice before the Office in any other proceeding in the last three
`
`years.
`
`viii. I am an experienced litigation attorney, with experience in many
`
`2
`
`ZOND 2002
`
`
`
`Patent No. 6,896,773
`IPR2014-00726
`
`litigations involving patent infringement in District Courts across the
`
`country, including experience with fact and expert document and
`
`deposition discovery, claim construction, Markman hearings, motion
`
`practice, trials and hearings, and investigations before the
`
`International Trade Commission.
`
`ix.
`
`I am counsel for Patent Owner Zond, LLC, the plaintiff in related on-
`
`going litigations in which U.S. Patent Nos. 6805779, 6806652,
`
`6853142, 7147759, 7604716, 7808184, 7811421, 6896775, 8125155,
`
`and 6896773 are and were asserted by the Patent Owner. I am
`
`familiar with the subject matter at issue in this proceeding as a result
`
`of my representation of Zond, LLC, in the related litigation, including
`
`the prior art that Petitioner presents in this proceeding, as well as
`
`issues of claim construction.
`
`Date: November 26, 2014
`
`/Tigran Vardanian/
`Tigran Vardanian
`RADULESCU LLP
`Empire State Building, Suite 6910
`350 Fifth Avenue,
`New York, NY 10118
`tigran@Radulescullp.com
`
`
`3
`
`ZOND 2002
`
`
`
`
`
`
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