`By: Herbert D. Hart III
`Sharon A. Hwang
`McAndrews, Held & Malloy, Ltd.
`500 W. Madison St., 34th Floor
`Chicago, IL 60661
`Tel: 312-775-8000
`Fax: 312-775-8100
`E-mail:
`hhart@mcandrews-ip.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`ERICSSON INC. and
`TELEFONAKTIEBOLAGET LM ERICSSON
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES II LLC
`Patent Owner
`_____________
`
`Case IPR2014-01195
`Patent No. 7,787,431
`_____________
`
`DECLARATION OF RAJENDRA A. CHIPLUNKAR
`
`1
`
`
`
`
`
`
`
`
`
`I, Rajendra A. Chiplunkar, declare as follows:
`
`1.
`
`I am an associate with the law firm of McAndrews, Held and Malloy,
`
`Ltd. in Chicago, Illinois.
`
`2.
`
`I have been practicing law for more than two years. My practice
`
`during that time has focused on intellectual property litigation, and particularly,
`
`patent litigation.
`
`3.
`
`I am a member in good standing of the Bar of the State of Illinois and
`
`am admitted to practice in the U.S. District Court for the Northern District of
`
`Illinois.
`
`4.
`
`I have been admitted to practice pro hac vice in other Federal District
`
`courts.
`
`5.
`
`I am the Secretary of the Illinois State Bar Association Intellectual
`
`Property Council.
`
`6.
`
`I have experience in fact and expert document and deposition
`
`discovery, and motion practice before U.S. District Courts in connection with
`
`patent infringement litigation matters.
`
`7.
`
`Prior to entering the field of law, I was employed as an electrical
`
`engineer by Motorola Inc. for over ten years. At Motorola, I contributed to the
`
`design of telecommunication equipment such as base stations. Through my work
`
`
`
`2
`
`
`
`at Motorola Inc., I gained valuable experience in the technologies that I believe are
`
`relevant to the challenged Patent and the alleged prior art references.
`
`8.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`9.
`
`No court or administrative body has ever denied my application for
`
`admission to practice.
`
`10. No court or administrative body has ever sanctioned me or cited me
`
`for contempt.
`
`11.
`
`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 37 C.F.R.
`
`Section 42.
`
`12.
`
`I agree to be subject to the United States Patent and Trademark
`
`Office’s 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).
`
`13.
`
`I have spent substantial time reviewing and analyzing the patent at
`
`issue in this proceeding, the patent file history, the Petition, the references cited,
`
`and the Declarations of Dr. Haas, the Petitioner’s Expert. I am familiar with the
`
`invalidity arguments advanced by the Petitioner.
`
`14.
`
`I have helped formulate the non-obviousness arguments that were
`
`advanced in the Patent Owner Response filed in this proceeding.
`3
`
`
`
`
`
`15.
`
`I attended the cross-examination of Petitioner’s Expert Declarant, Dr.
`
`Haas and the cross-examination of Patent Owner’s Expert Declarant, Dr. Zeger.
`
`17.
`
`I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that these statements are made with the knowledge
`
`that willful false statements and the like are punishable by fine, imprisonment, or
`
`both, under Section 1001 of Title 18 of the United States Code.
`
`Dated: August 6, 2015
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`
`
`/s/ Rajendra A. Chiplunkar
`Rajendra A. Chiplunkar
`McAndrews, Held and Malloy, Ltd.
`500 W. Madison Street
`Suite 3400
`Chicago, IL 60661
`rchiplunkar@mcandrews-ip.com
`
`
`
`
`
`4
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