`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`TSMC NORTH AMERICA CORPORATION,
`FUJITSU SEMICONDUCTOR LIMITED,
`FUJITSU SEMICONDUCTOR AMERICA, INC.,
`ADVANCED MICRO DEVICES, INC., RENESAS ELECTRONICS
`CORPORATION, RENASAS ELECTRONICS AMERICA, INC.,
`GLOBAL FOUNDRIES U.S., INC., GLOBAL FOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBAL FOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG, TOSHIBA AMERICA ELECTRONIC
`COMPONENTS, INC., TOSHIBA AMERICA INC., TOSHIBA
`AMERICA INFORMATION SYSTEMS, INC.,
`TOSHIBA CORPORATION, and
`THE GILLETTE COMPANY,
`Petitioners,
`
`v.
`
`ZOND, LLC,
`Patent Owner
`____________________________________________
`
`Case IPR2014-009171
`Patent 6,805,779 B2
`____________________________________________
`
`
`AFFIDAVIT OF ANTHONY J. FITZPATRICK IN SUPPORT OF
`PETITIONERS’ MOTION FOR PRO HAC VICE ADMISSION
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`1 Cases IPR2014-00918, IPR2014-01074, and IPR2014-01025 have been joined
`with the instant proceeding.
`
`Page 1 of 4
`
`TSMC-1416
`
`TSMC vs. Zond, Inc., IPR2014-00917
`Page 1 of 4
`
`
`
`AFFIDAVIT OF ANTHONY J. FITZPATRICK
`
`I, Anthony J. Fitzpatrick, being duly sworn and upon oath, hereby attest to
`
`the following:
`
`i.
`
`I am a member in good standing of the Massachusetts Bar (#564324), as
`
`well as the following Federal Courts:
`
`a) U.S. Court of Appeals for the First Circuit;
`
`b) U.S. Court of Appeals for the Federal Circuit;
`
`c) U.S. District Court for the District of Massachusetts;
`
`d) U.S. District Court for the Eastern District of Wisconsin; and
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`e) Supreme Court of the United States.
`
`ii.
`
`iii.
`
`I have not been suspended or disbarred from practice before any court or
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`administrative body.
`
`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.
`
`
`
`Page 2 of 4
`
`TSMC-1416
`Page 2 of 4
`
`
`
`AFFIDAVIT OF ANTHONY J. FITZPATRICK
`
`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
`
`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 Petitioner Taiwan Semiconductor Manufacturing
`
`Company, Ltd., the defendant in related on-going litigations in which
`
`U.S. Patent Nos. 6805779, 6806652, 6853142, 7147759, 7604716,
`
`7808184, and 7811421, 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 Taiwan Semiconductor Manufacturing Company,
`
`
`
`Page 3 of 4
`
`TSMC-1416
`Page 3 of 4
`
`
`
`AFFIDAVIT OF ANTHONY J. FITZPATRICK
`
`Ltd. in the related litigation, including the prior art that Petitioner
`
`presents in this proceeding, as well as issues of claim construction.
`
`Date: 11/20/2014
`
`
`
`
`
`
`
`
`
` /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
`
`
`
`
`
`
`Page 4 of 4
`
`TSMC-1416
`Page 4 of 4
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