`LG Electronics U.S.A., Inc., and
`LG Electronics Mobilecomm U.S.A., Inc.
`
`Paper __
`
`Filed: March 10, 2015
`
`By:
`
`Jason Shapiro, Lead Counsel
`Soumya P. Panda, Back-up Counsel
`ROTHWELL, FIGG, ERNST & MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`Emails: jshapiro@rothwellfigg.com
`spanda@rothwellfigg.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG ELECTRONICS, INC., LG ELECTRONICS U.S.A., INC., AND
`LG ELECTRONICS MOBILECOMM U.S.A, INC.,
`Petitioner,
`
`v.
`
`CYPRESS SEMICONDUCTOR CORP.,
`Patent Owner.
`
`Case IPR2014-01386
`Patent 6,012,103
`
`DECLARATION OF STEVEN LIEBERMAN IN SUPPORT OF
`PETITIONER'S MOTION FOR ADMISSION PRO HAC VICE
`
`
`
`Case IPR2014-01386
`Patent 6,012,103
`
`I, Steven Lieberman, declare as follows:
`
`1.
`
`I have been practicing in the field of intellectual property, and
`
`particularly, patent litigation, for twenty-four years.
`
`2.
`
`I am a member in good standing of the Bars of the State of New York
`
`and the District of Columbia. I am admitted to practice in the United States
`
`District Courts for the District of Columbia, Maryland, the Northern District of
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`California, and the Northern, Eastern, and Southern Districts of New York. I am
`
`also admitted to practice in the Courts of Appeals for the District of Columbia, the
`
`Second Circuit, the Fourth Circuit, the Federal Circuit, and the United States
`
`Supreme Court.
`
`3.
`
`I am a past President of the Giles S. Rich American Inn of Court, the
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`D.C. Inn devoted to the practice of intellectual property law.
`
`4.
`
`I have been in private practice since 1985 and have been litigating
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`patent cases since 1990, primarily as lead counsel.
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`5.
`
`I have never been suspended or disbarred from practice before any
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`court or administrative body.
`
`6.
`
`I have never had a court or administrative body deny my application
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`for admission to practice.
`
`7.
`
`No sanctions or contempt citations have ever been imposed against
`
`me by any court or administrative body.
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`2
`
`
`
`Case IPR2014-01386
`Patent 6,012,103
`I have read and will comply with the Office Patent Trial Practice
`
`8.
`
`Guide and the Board's Rules ofPractice for Trials, as set forth in Part 42 of37
`
`C.F.R.
`
`9.
`
`I agree to be subject to the USPTO Rules of Professional Conduct set
`
`forth in 37 C.P.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.P.R. §
`
`11.19(a). I also agree to be subject to the USPTO Rules of Professional Conduct
`
`as set forth in Changes to Representation of Others Before the United States Patent
`
`and Trademark Office; Final Rule, 78 Fed. Reg. 20180 (Apr. 3, 2013) (effective
`
`May 3, 2013).
`
`10.
`
`In the past three (3) years, I have been admitted pro hac vice in the
`
`following proceedings before the United States Patent and Trademark Office:
`
`-
`
`-
`
`-
`
`-
`
`-
`
`-
`
`International Securities Exchange, LLC v. Chicago Board Options
`Exchange, Incorporated, CBM2013-00049;
`
`International Securities Exchange, LLC v. Chicago Board Options
`Exchange, Incorporated, CBM2013-00050;
`
`International Securities Exchange, LLC v. Chicago Board Options
`Exchange, Incorporated, CBM2013-00051;
`
`International Securities Exchange, LLC v. Chicago Board Options
`Exchange, Incorporated, IPR2014-00097;
`
`International Securities Exchange, LLC v. Chicago Board Options
`Exchange, Incorporated, IPR2014-00098;
`
`International Securities Exchange, LLC v. Chicago Board Options
`Exchange, Incorporated, IPR2014-00099;
`
`3
`
`
`
`Case IPR2014-01386
`Patent 6,012,103
`- Toshiba Samsung Storage Technology Korea Corporation v. LG
`Electronics, Inc., IPR2014-00204; and
`
`- Toshiba Samsung Storage Technology Korea Corporation v. LG
`Electronics, Inc., IPR2014-00205.
`
`11.
`
`I am familiar with the subject matter at issue in this proceeding. I am
`
`lead counsel in the Cypress Semiconductor Corp. v. LG Electronics, Inc. et al.
`
`patent infringement litigation (Case No. 4:13-cv-04034-SBA), which is pending in
`
`the United States District Court for the Northern District of California and involves
`
`the same patent at issue in this proceeding.
`
`12.
`
`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 so made are punishable by fine or
`
`imprisonment, or both, under Section 1001 of Title 18 of the United States Code
`
`and that such willful false statements may jeopardize the validity of U.S. Patent
`
`No. 6,012,103.
`
`Date: March 9, 2015
`
`By:_-/--+------------
`ven Lieberman
`ROTHWELL, FIGG, ERNST &
`MANBECK, P.C.
`607 14th St., N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`Email: slieberm@rothwellfigg.com
`
`4
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`
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`Case IPR2014-01386
`Patent 6,012,103
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`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 10th day of March, 2015, a true and correct copy
`
`of the foregoing DECLARATION OF STEVEN LIEBERMAN IN SUPPORT
`
`OF PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE was
`
`served, via electronic mail upon the following counsel for Patent Owner Cypress
`
`Semiconductor Corp.:
`
`
`
`
`
`Robert R. Laurenzi, Esq.
`Kaye Scholer LLP
`425 Park Avenue
`New York, NY 10022
`Phone: (212) 836-8000
`Email: robert.laurenzi@kayescholer.com
`
`Robert S. Magee, Esq.
`Kaye Scholer LLP
`Two Palo Alto Square, Suite 400
`3000 El Camino Real
`Palo Alto, CA 94306
`Phone: (650) 319-4500
`Email: robert.magee@kayescholer.com
`
`
`
`
` /Erik van Leeuwen/
`Erik van Leeuwen
`Litigation Operations Coordinator
`Rothwell, Figg, Ernst & Manbeck, P.C.
`
`
`
`
`
`