`By:
`Justin B. Kimble (jkimble@bcpc-law.com)
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`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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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
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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 IPR2014-01357
`U.S. Patent No. 6,755,547
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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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`Case IPR2014-01357
`Patent 6,755,547
`I, Jeffrey R. Bragalone, make the following declaration based on my
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`own personal knowledge and, if called to testify before the court, could and would
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`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.,
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`located 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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`2.
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`3.
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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
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42
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`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
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`forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction
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`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
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`before the PTAB in sixteen other proceedings, three of which have
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`Case IPR2014-01357
`Patent 6,755,547
`been granted and the rest remain pending. Five of the pro hac vice
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`motions involve the same parties as this proceeding and also involve
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`light emitting panel assemblies:
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`i. IPR2014-01092 (pending);
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`ii. IPR2014-01094 (pending);
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`iii. IPR2014-01095 (pending);
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`iv. IPR2014-00096 (pending); and
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`v. IPR2014-01097 (pending).
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`The remaining eleven pro hac vice motions involve eleven other
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`IPRs all unrelated to this petition:
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`vi. CBM2014-00166 (granted);
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`vii. IPR2014-00785 (pending);
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`viii. IPR2014-00810 (pending);
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`ix. IPR2014-00824 (granted);
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`x. IPR2014-00825 (granted);
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`xi. IPR2014-01278 (pending);
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`xii. IPR2014-01282 (pending);
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`xiii. IPR2014-01283 (pending);
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`xiv. IPR2015-00153 (pending);
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`xv. IPR2015-00155 (pending); and
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`Case IPR2014-01357
`Patent 6,755,547
`xvi. IPR2015-00156 (pending).
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`I have not applied to appear pro hac vice in any other proceeding
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`before the PTAB.
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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 Patent Owner Innovative Display Technologies in
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`its assertion of U.S. Patent No. 6,755,547 (the patent at issue-in this
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`petition) and its related patents in numerous cases pending in the
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`District of Delaware and the Eastern District of Texas. See, e.g.,
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`Innovative Display Technologies LLC v. Acer Inc. et al., No. 2:13-cv-
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`00522 (E.D. Tex., filed June 28, 2013); see also Delaware Display
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`Group LLC et al. v. Sony Corp et al., No. 1:13-cv-02111 (D. Del.,
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`filed Dec. 31, 2013). As lead counsel in those actions, I have
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`familiarized myself with the subject matter at issue in this proceeding,
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`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
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`in this petition as well as its related patents, all of which concern light
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`emitting panel assemblies. Also in those lawsuits, I have developed
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`infringement allegations that assert the patent-at-issue in this petition
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`against various light emitting panel assemblies, including those found
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`in smart phones, tablets, laptop computers, and televisions to name a
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`4
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`Case IPR2014-01357
`Patent 6,755,547
`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
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`panel assemblies such as those found in the patent-at-issue in this
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`proceeding.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 28th day of November, 2014.
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`Jeffrey R. Bragalone
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 West
`Dallas, TX 75201
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`5
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