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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`CISCO SYSTEMS, INC. and QUANTUM CORPORATION,
`Petitioners,
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`V.
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`CROSSROADS SYSTEMS, INC.,
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`Patent Owner.
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`Case IPR2014-01463
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`Patent 7,934,041
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`AFFIDAVIT OF MATTHEW C. GAUDET IN SUPPORT OF
`PETITIONERS’ MOTION FOR PRO HAC VICE ADMISSION
`
`CISCO et al. v. CROSSROADS
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`CQ-1014 I |PR2014-01463
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`Page 1 of 4
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`
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`IPR2014-01463
`Affidavit Of Matthew C. Gaudet in Support of
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`Petitioners’ Motion for Pro Hac Vice Admission U.S. Patent No. 7,934,041
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`I, Matthew C. Gaudet, being duly sworn and upon oath, herebynattest to the
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`following:
`i.
`I am a member in good standing ofthe Bar of Georgia (#287789), as well
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`as the following Federal Courts:
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`a) U.S. Northern District of Georgia;
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`b) U.S. Court of Appeals, 11”‘ Circuit;
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`c) U.S. Middle District of Georgia; and
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`d) U.S. 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 court
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`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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`CQ-1014 I |PR2014-01463
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`Page 2 of 4
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`
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`Affidavit Of Matthew C. Gaudet in Support of
`Petitioners’ Motion for Pro Hac Vice Admission
`
`IPR2014-01463
`
`U.S. Patent No. 7,934,041
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`Vi.
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`I will be subject to the USPTO Rules of Professional Conduct set forth in
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`37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R.
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`§ 11.19(a).
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`vii.
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`In the last three years, I have not applied to appear pro hac vice before
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`the Office.
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`I am concurrently applying to appear pro hac vice before the Office in
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`the following proceedings:
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`a) Cisco Systems, Inc., et al. v. Crossroads Systems, Inc.,
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`IPR2014-01544.
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`b) Cisco Systems, Inc., et al. v. Crossroads Systems, Inc.,
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`IPR2014-01226.
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`viii.
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`I am an experienced litigation attorney, with experience in many
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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 lntemational
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`Trade Commission.
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`ix.
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`1 am counsel for Petitioner Cisco Systems, Inc., the defendant in an on-
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`going litigation in which U.S. Patent No. 7,934,041 is asserted by the
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`_ 2 -
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`CQ-1014 I |PR2014-01463
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`Page 3 of 4
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`
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`Affidavit Of Matthew C. Gaudet in Support of
`Petitioners’ Motion for Pro Hac Vice Admission
`
`IPR2014—01463
`U.S. Patent No. 7,934,041
`
`Patent Owner.
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`I am familiar with the subject matter at issue in this
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`proceeding as a result of my representation of Cisco Systems in the
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`related litigation, including the prior art that Petitioners present in this
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`proceeding, as well as issues of claim construction.
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`Date: May 11, 2015
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`”l'“'*Q (€030
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`Matthew C. Gaudet
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`DUANE MORRIS LLP
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`1075 Peachtree St. NE, Suite 2000
`Atlanta, GA 30309-3929
`Telephone: (404) 253-6902
`Fax: (404) 393-1908
`Email: MCGaudet@duanemorris.com
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`CQ-1014 I |PR2014-01463
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`Page 4 of 4