`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`TSMC NORTH AMERICA CORPORATION,
`FUJITSU SEMICONDUCTOR LIMITED, and
`FUJITSU SEMICONDUCTOR AMERICA, INC.,
`
`Petitioners,
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`v.
`
`ZOND, LLC,
`Patent Owner
`____________________________________________
`
`Case IPR2014-008031
`Patent 7,808,184 B2
`____________________________________________
`
`AFFIDAVIT OF ANTHONY J. FITZPATRICK IN SUPPORT OF
`PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION
`
`1 Case IPR2014-00858 has been joined with the instant proceeding.
`Page 1 of 4
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`TSMC-1124 / IPR2014-00803
`TSMC v Zond, LLC
`Page 1 of 4
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`
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`AFFIDAVIT OF ANTHONY J. FITZPATRICK
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`I, Anthony J. Fitzpatrick, being duly sworn and upon oath, hereby attest to
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`the following:
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`i.
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`I am a member in good standing of the Massachusetts Bar (#564324), as
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`well as the following Federal Courts:
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`a) U.S. Court of Appeals for the First Circuit;
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`b) U.S. Court of Appeals for the Federal Circuit;
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`c) U.S. District Court for the District of Massachusetts;
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`d) U.S. District Court for the Eastern District of Wisconsin; and
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`e) Supreme Court of the United States.
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`ii.
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`I have not been suspended or disbarred from practice before any court or
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`administrative body.
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`iii.
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`I have never had an application for admission to practice before any court
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`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 Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of the
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`Code of Federal Regulations.
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`Page 2 of 4
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`TSMC-1124 / IPR2014-00803
`Page 2 of 4
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`AFFIDAVIT OF ANTHONY J. FITZPATRICK
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`vi.
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`I will be subject to the USPTO Rules of Professional Conduct set forth in
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`37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R.
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`§ 11.19(a).
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`vii. Other than presently applying to appear Pro Hac Vice before the Office
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`in connection with the Inter Partes Review proceedings of the patents
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`listed below in section ix, I have not applied to appear Pro Hac Vice
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`before the Office in any other proceeding in the last three years.
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`viii.
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`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 International
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`Trade Commission.
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`ix.
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`I am counsel for Petitioner Taiwan Semiconductor Manufacturing
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`Company, Ltd., the defendant in related on-going litigations in which
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`U.S. Patent Nos. 6805779, 6806652, 6853142, 7147759, 7604716,
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`7808184, and 7811421, 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 of
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`my representation of Taiwan Semiconductor Manufacturing Company,
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`Page 3 of 4
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`TSMC-1124 / IPR2014-00803
`Page 3 of 4
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`AFFIDAVIT OF ANTHONY J. FITZPATRICK
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`Ltd. in the related litigation, including the prior art that Petitioner
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`presents in this proceeding, as well as issues of claim construction.
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`Date: 10/28/2014
`
`/Anthony J. Fitzpatrick/
`Anthony J. Fitzpatrick
`DUANE MORRIS LLP
`100 High Street, Suite 2400
`Boston, MA 02110-1724
`Telephone: 857-488-4220
`Fax: 857-488-4201
`Email: AJFitzpatrick@duanemorris.com
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`Page 4 of 4
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`TSMC-1124 / IPR2014-00803
`Page 4 of 4