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`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`ORACLE CORPORATION, NETAPP INC. and
`HUAWEI TECHNOLOGIES CO., LTD.
`Petitioner,
`
`v.
`
`CROSSROADS SYSTEMS, INC.
`Patent Owner
`
`____________
`
`Case IPR2014-01209
`Patent No. 7,051,147
`____________
`
`
`
`DECLARATION OF SCOTT S. CROCKER IN SUPPORT OF
`PATENT OWNER’S UNOPPOSED MOTION FOR
`PRO HAC VICE ADMISSION OF SCOTT S. CROCKER
`
`
`
`1
`
`

`

`
`
`I, Scott S. Crocker, make the following declaration based on my own
`
`personal knowledge:
`
`1.
`
`I am a partner in the law firm of Sprinkle IP Law Group, P.C. My
`
`fellow partner, Steve Sprinkle is lead counsel for Crossroads Systems, Inc.
`
`(“Crossroads”) in this proceeding, related inter partes review proceedings before
`
`the Board, and several patent suits that are presently pending in the Western
`
`District of Texas.
`
`2.
`
`I was admitted to practice before the Supreme Court of Texas in 1994
`
`and I am a member in good standing of the Texas State Bar. I am also admitted to
`
`practice in the District Courts for the Western District of Texas, Northern District
`
`of Texas, and Eastern District of Texas.
`
`3.
`
`I have never been suspended or disbarred by any court or
`
`administrative body.
`
`4.
`
`I have never been denied an application for pro hac vice admission to
`
`practice before any court or administrative body.
`
`5.
`
`No sanctions or contempt citations have been imposed against me by
`
`any court or administrative body.
`
`6.
`
`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 37 C.F.R.
`
`
`
`
`
`

`

`
`
`7.
`
`I agree that I will be subject to the USPTO’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).
`
`8.
`
`I am concurrently applying for pro hac vice admission in the
`
`following proceedings before the USPTO:
`
` IPR2014-01197 (United States Patent No. 6,425,035) by Oracle
`
`Corporation, NetApp, Inc. and Huawei Technologies Co. Ltd.
`
` IPR2014-01207 (United States Patent No. 7,051,147) by Oracle
`
`Corporation, NetApp, Inc. and Huawei Technologies Co. Ltd.
`
` IPR2014-01226 (United States Patent No. 6,425,035) by Cisco
`
`Systems, Inc. and Quantum Corporation
`
`9.
`
`I obtained my J.D. in 1994 from the University of Texas School of
`
`Law in Austin, Texas. I have been in civil litigation for over 20 years, and I have
`
`been litigating patent cases since 2006. I consider myself to be very familiar with
`
`the patent laws of the United States.
`
`10.
`
`I have read Crossroads Systems’ U.S. Patent No. 7,051,147, which is
`
`the patent under review in this proceeding. Ex. 1001. I have also read the Petition
`
`for Inter Partes Review in this proceeding, including the alleged prior art, the
`
`supporting Declaration of Jeffery S. Chase, Ph.D, and other exhibits. I have also
`
`
`
`
`
`

`

`
`
`read Patent Owner’s Preliminary Response and its associated exhibits. I have also
`
`read the Board’s decision instituting inter partes review in this proceeding.
`
`11.
`
`I am counsel of record for Crossroads in the following patent cases
`
`which relate to the patent under review:
`
` Crossroads Systems, Inc. v. Oracle Corporation
`
`Case No. 1:13-CV-00895-SS (W.D. Tex.)
`
` Crossroads Systems, Inc. v. Huawei Technologies Co. Ltd. et al.
`
` Case No. 1:13-CV-01025-SS (W.D. Tex.)
`
` Crossroads Systems, Inc. v. Cisco Systems, Inc.,
`
`Case No. 1:14-CV-00148-SS (W.D. Tex.)
`
` Crossroads Systems, Inc. v. NetApp, Inc.,
`
`Case No. 1:14-CV-00149-SS (W.D. Tex.)
`
` Crossroads Systems, Inc. v. Quantum Corporation,
`
`Case No. 1:14-CV-00150-SS (W.D. Tex.)
`
`12. Prior to becoming counsel of record in the above cases, I was
`
`involved in the Claim Construction process for the patent under review and other
`
`members of its patent family. I was involved in the preparation of arguments for
`
`Crossroads’ Claim Construction Contentions as well as its presentation at the two-
`
`day hearing before a special master.
`
`
`
`
`
`

`

`
`
`13.
`
`I have read the Report and Recommendation of the Special Master
`
`regarding Claim Construction in the above listed district court cases.
`
`14. Through my involvement in the district court litigations and my own
`
`legal and technical research and consultations, I am familiar with the technology of
`
`the patent under review and the issues associated with this proceeding.
`
`15.
`
`I declare under penalty of perjury of the laws of the United States that
`
`the foregoing is true and correct.
`
`Executed this 25th day of February, 2015 at Austin, Texas.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/Scott S. Crocker/
`Scott S. Crocker
`
`
`
`
`
`

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