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`Patent No. 7,604,716
`IPR2014-01100
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`_____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________
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`GLOBAL FOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN MODULE
`TWO LLC & CO. KG, and THE GILLETTE COMPANY,
`Petitioners
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`v.
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`ZOND, LLC
`Patent Owner
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`v.
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`ZOND, LLC
`Patent Owner
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`_____________________
`Case No. IPR2014-011001
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`Patent 7,604,716 B2
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`_____________________
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`AFFIDAVIT OF ETAI LAHAV IN SUPPORT OF PATENT OWNER’S
`MOTION FOR PRO HAC VICE ADMISSION
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`I, Etai Lahav, being duly sworn and upon oath, hereby attest to the
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`following:
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`i.
`I am a member in good standing of the New York Bar, as well as the
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`1 Case IPR 2014-00973 has been joined with the instant proceeding.
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`GLOBAL FOUNDRIES U.S., INC. et al. v. ZOND, LLC
`IPR 2014-01100 ZOND EX. 2001
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`following Federal Courts:
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`Patent No. 7,604,716
`IPR2014-01100
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`a) U.S. District Court for the Eastern District of New York;
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`b) U.S. District Court for the Southern District of New York; and
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`c) U.S. District Court for the Eastern District of Texas.
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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
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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 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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`vi.
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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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`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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`2
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`ZOND 2001
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`I am an experienced litigation attorney, with experience in many
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`Patent No. 7,604,716
`IPR2014-01100
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`viii.
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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 Patent Owner Zond, LLC, the plaintiff in related on-
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`going litigations in which U.S. Patent Nos. 6805779, 6806652, 6853142,
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`7147759, 7604716, 7808184, 7811421, 6896775, 8125155, and 6896773
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`are and were asserted by the Patent Owner. I am familiar with the
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`subject matter at issue in this proceeding as a result of my representation
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`of Zond, LLC, in the related litigation, including the prior art that
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`Petitioner presents in this proceeding, as well as issues of claim
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`/Etai Lahav/
`Etai Lahav
`RADULESCU LLP
`The Empire State Building
`350 Fifth Avenue, Suite 6910
`New York, NY 10118
`etai@Radulescullp.com
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`construction.
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`Date: November 25, 2014
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`3
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`ZOND 2001
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`Patent No. 7,604,716
`IPR2014-01100
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`4
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`ZOND 2001