`By:
`Justin B. Kimble (jkimble@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`Tel: 214.785.6670
`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 CO., LTD.
`Petitioner
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`v.
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`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`Patent Owner
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`Case IPR2014-01097
`U.S. Patent No. 7,300,194
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`
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`PRO HAC VICE MOTION TO ADMIT ATTORNEY T. WILLIAM
`KENNEDY PURSUANT TO 37 C.F.R. § 42.10(c)
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`EXHIBIT 2007: DECLARATION OF T. WILLIAM KENNEDY
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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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`
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`Case IPR2014-01097
`Patent 7,300,194
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`I, T. William Kennedy, make the following declaration based on my own
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`personal knowledge and, if called to testify before the court, could and would testify
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`as follows:
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`1.
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`I am an attorney with the law firm of Bragalone Conroy, P.C., located
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`2.
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`3.
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`at 2200 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
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`practice before 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
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`any court or administrative body.
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`6.
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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 37
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`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
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`in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37
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`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
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`the PTAB in one other proceeding (IPR2014-01096), the motion for
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`2
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`Case IPR2014-01097
`Patent 7,300,194
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`which was filed concurrently with this motion. I intend to file pro hac
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`vice motions for the remainder of the IPRs asserted in this patent family.
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`9.
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`I have familiarity with the subject matter at issue in this proceeding. I
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`currently represent the Patent Owner in its assertion of the patent at
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`issue in this proceeding and its related patents in numerous cases
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`pending in the District of Delaware and the Eastern District of Texas.
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`See, e.g., Innovative Display Technologies LLC v. Sprint Corporation
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`et al., No. 2:13-cv-00721 (E.D. Tex., filed June 25, 2014); see also
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`Delaware Display Group LLC et al. v. Sony Corp et al., No. 1:13-cv-
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`02111 (D. Del., filed Dec. 31, 2013). As counsel in those actions, I have
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`become very familiar the subject matter at issue in this proceeding, i.e.,
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`light emitting panel assemblies. Moreover, during the course of those
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`lawsuits, I have analyzed the prior art involved in this petition as it
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`relates to the patent-at-issue as well as its related patents, all of which
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`concern light emitting panel assemblies. Furthermore, in those lawsuits
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`I have developed infringement allegations that assert the patent-at-issue
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`in this petition against various light emitting panel assemblies,
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`including those found in smart phones, tablets, laptop computers, and
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`televisions to name a few. In my role as counsel in those litigations, I
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`have spent significant time learning the technology involved in light
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`3
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`Case IPR2014-01097
`Patent 7,300,194
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`emitting panel assemblies such as those found in the patent-at-issue in
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`this proceeding.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 10th day of April, 2015.
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`T. William Kennedy
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 West
`Dallas, TX 75201
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`4
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