`By:
`Justin B. Kimble (jkimble@bcpc-law.com)
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`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
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`Bragalone Conroy P.C.
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`2200 Ross Ave.
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`Suite 4500 – West
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`Dallas, TX 75201
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`Tel: 214.785.6670
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`Fax: 214.786.6680
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LG DISPLAY, LTD.
`Petitioner
`v.
`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`Patent Owner
`
`
`Case IPR2014-01092
`U.S. Patent No. 7,434,974
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`PRO HAC VICE MOTION TO ADMIT ATTORNEY JEFFREY R. BRAGALONE
`PURSUANT TO 37 C.F.R. § 42.10(c)
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`EXHIBIT 2001: DECLARATION OF JEFFREY R. BRAGALONE
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
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`Case IPR2014-01092
`Patent 7,434,974
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`I, Jeffrey R. Bragalone, make the following declaration based on my own personal
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`knowledge and, if called to testify before the court, could and would testify as follows:
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`1.
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`I am a shareholder with the law firm of Bragalone Conroy, P.C., located at 2200
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`2.
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`3.
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`Ross Avenue, Suite 4500-West, Dallas, TX 75201.
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`I am a member in good standing of the Texas State Bar.
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`I have never been subject to any suspensions or disbarments from practice before
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`any court or administrative body.
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`4.
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`None of my applications for admission to practice before any court or
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`administrative body has ever been denied.
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`5.
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`I have never been sanctioned nor had contempt citations imposed by any court or
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`administrative body.
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`6.
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`I have read and will comply with the Office Patent Trial Practice Guide and the
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`Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`7.
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`I will be subject to the USPTO Rules of Professional Conduct set forth in 37 C.F.R.
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`§§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`8.
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`During the past three years, I have applied to appear pro hac vice before the Office
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`in the proceedings IPR2014-00785, IPR2014-00810, IPR2014-00824, and
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`IPR2014-00825 on behalf of the patent owner in those matters, Securus
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`Technologies, Inc. I have also applied to appear pro hac vice before the Office in
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`the following proceedings: IPR2014-01094, IPR2014-01095, IPR2014-01096, and
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`IPR2014-01097, the motions for which are filed concurrently with this motion. All
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`of those proceedings involve the same Petitioner and Patent Owner as this
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`2
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`Case IPR2014-01092
`Patent 7,434,974
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`proceeding as well as patents related to the patent-at-issue in this proceeding. Each
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`of the pro hac vice motions discussed in this paragraph is currently pending.
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`9.
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`I have familiarity with the subject matter at issue in this proceeding. I currently
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`represent Patent Owner Innovative Display Technologies in its assertion of U.S.
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`Patent No. 7,434,974 (the patent at issue-in this petition) and its related patents in
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`numerous cases pending in the District of Delaware and the Eastern District of
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`Texas. See, e.g., Innovative Display Technologies LLC v. Acer Inc. et al., No. 2:13-
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`cv-00522 (E.D. Tex., filed June 28, 2013); see also Delaware Display Group LLC
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`et al. v. Sony Corp et al., No. 1:13-cv-02111 (D. Del., filed Dec. 31, 2013). As lead
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`counsel in those actions, I have familiarized myself with the subject matter at issue
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`in this proceeding, i.e., light emitting panel assemblies. During the course of those
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`lawsuits, I have developed invalidity defenses for the patent-at-issue in this petition
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`as well as its related patents, all of which concern light emitting panel assemblies.
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`Also in those lawsuits, I have developed infringement allegations that assert the
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`patent-at-issue in this petition against various light emitting panel assemblies,
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`including those found in smart phones, tablets, laptop computers, and televisions to
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`name a few. In my role as the lead attorney in those litigations, I have spent
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`significant time learning the technology involved in light emitting panel assemblies
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`such as those found in the patent-at-issue in this proceeding.
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`3
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`Case IPR2014-01092
`Patent 7,434,974
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Jeffrey R. Bragalone
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 West
`Dallas, TX 75201
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`
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`Executed this 11th day of August, 2014.
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`4
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