`IPR2014-00799
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________
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`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`TSMC NORTH AMERICA CORPORATION, ADVANCED MICRO DEVICES,
`INC., RENESAS ELECTRONICS CORPORATION, RENESAS ELECTRONICS
`AMERICA, INC., GLOBALFOUNDRIES U.S., INC., GLOBALFOUNDRIES
`DRESDEN MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG, TOSHIBA AMERICA ELECTRONIC
`COMPONENTS, INC., TOSHIBA AMERICA INC., TOSHIBA AMERICA
`INFORMATION SYSTEMS, INC., TOSHIBA CORPORATION, and
`THE GILLETTE CO.
`Petitioners
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`v.
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`ZOND, LLC
`Patent Owner
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`_____________________
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`Inter Partes Review Case No. IPR2014-007991
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`Patent 7,808,184 B2
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`_____________________
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` AFFIDAVIT OF TIGRAN VARDANIAN IN SUPPORT OF PATENT
`OWNER’S MOTION FOR PRO HAC VICE ADMISSION
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`I, Tigran Vardanian, being duly sworn and upon oath, hereby attest to
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`1 Cases IPR 2014-00855, IPR 2014-00955, and IPR 2014-01042 have been joined
`with the instant proceeding.
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`1
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`ZOND 2010
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`the following:
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`Patent No. 7,808,184
`IPR2014-00799
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`i.
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`I am a member in good standing of the New York and Illinois Bars,
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`as well as the following Federal Courts:
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`a) U.S. District Court for the Northern District of Illinois; and
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`b) U.S. District Court for the Eastern District of Michigan.
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`ii.
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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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`iii.
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`I have never had an application for admission to practice before any
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`court or administrative body denied.
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`iv. No sanction or contempt citation has been imposed against me by any
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`court or administrative body.
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`v.
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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
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`of the Code of Federal Regulations.
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`vi.
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`I will be subject to the USPTO Rules of Professional Conduct set
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`forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction
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`under 37 C.F.R. § 11.19(a).
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`vii. Other than presently applying to appear Pro Hac Vice before the
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`Office in connection with the Inter Partes Review proceedings of the
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`patents listed below in section ix, I have not applied to appear Pro
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`2
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`ZOND 2010
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`Patent No. 7,808,184
`IPR2014-00799
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`Hac Vice before the Office in any other proceeding in the last three
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`years.
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`viii. I am an experienced litigation attorney, with experience in many
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`litigations involving patent infringement in District Courts across the
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`country, including experience with fact and expert document and
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`deposition discovery, claim construction, Markman hearings, motion
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`practice, trials and hearings, and investigations before the
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`International Trade Commission.
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`ix.
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`I am counsel for Patent Owner Zond, LLC, the plaintiff in related on-
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`going litigations in which U.S. Patent Nos. 6805779, 6806652,
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`6853142, 7147759, 7604716, 7808184, 7811421, 6896775, 8125155,
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`and 6896773 are and were asserted by the Patent Owner. I am
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`familiar with the subject matter at issue in this proceeding as a result
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`of my representation of Zond, LLC, in the related litigation, including
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`the prior art that Petitioner presents in this proceeding, as well as
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`issues of claim construction.
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`3
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`ZOND 2010
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`Date: November 26, 2014
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`Patent No. 7,808,184
`IPR2014-00799
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`/Tigran Vardanian/
`Tigran Vardanian
`RADULESCU LLP
`Empire State Building, Suite 6910
`350 Fifth Avenue,
`New York, NY 10118
`tigran@Radulescullp.com
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`4
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`ZOND 2010