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`I, Jonathan R. DeFosse, declare as follows:
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`1. I am a member in good standing of the Bar of Virginia and the Bar of the
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`District of Columbia, as well as the following Federal Courts:
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`United States District Court for the District of Columbia;
`United States District Court for the Eastern District of Virginia;
`United States District Court for the Eastern District of Texas;
`United States Court of Appeals for the Fourth Circuit;
`United States Court of Appeals for the Eleventh Circuit;
`United States Court of Appeals for the Federal Circuit.
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`2. I have not been suspended or disbarred from practice before any court or
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`administrative body.
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`3. I have never been denied admission to practice before any court or
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`administrative body.
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`4. I have never been sanctioned or cited for contempt by any court or
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`administrative body.
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`5. I have read and will comply with the Office Patent Trial Practice Guide and
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`the Board's Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`6. I will be subject to the USPTO Rules of Professional Conduct set forth in 37
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`C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`7. In the last three years, I have applied to appear pro hac vice before the
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`Office in the following inter partes review proceedings: IPR2014-00643,
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`
`
`1
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`IPR2015-00360 - Exh. 1025
`Mercedes-Benz USA LLC and
`Mercedes-Bez U.S. Int’l, Inc., Petitioners
`Innovative Display Technologies, Inc., Patent Owner
`
`
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`IPR2014-00644, IPR2014-00645, IPR2014-00646, and IPR2014-00647. I am
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`simultaneously applying to appear pro hac vice in the following inter partes
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`review proceedings: IPR2015-00359, IPR2015-00361, IPR2015-00363, IPR2015-
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`00366, and IPR2015-00368.
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`8. I have an established familiarity with the subject matter at issue in the
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`proceeding, because I am representing Petitioners as defendants in the related
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`proceeding, Innovative Display Technologies, LLC v. Mercedes-Benz U.S. Int’I,
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`Inc., et al., No. 2:14-cv-00535 (E.D. Tex.). In this related proceeding, Patent
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`Owner has asserted the following patents (among others) against Petitioners:
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`U.S. Patent No. 7,384,177
`U.S. Patent No. 7,300,194
`U.S. Patent No. 6,755,547
`U.S. Patent No. 7,404,660
`U.S. Patent No. 8,215,816
`U.S. Patent No. 7,434,974
`9. My experience representing Petitioner in this related proceeding, concerning
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`the same patents against the same Patent Owner, provides me with an established
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`familiarity with the subject matter at issue in the current proceedings.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Dated: March 6, 2015
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`
`
`
`
`/s/ Jonathan R. DeFosse
`Jonathan R. DeFosse
`SHEARMAN & STERLING LLP
`801 Pennsylvania Avenue, NW, Ste. 900
`Washington, DC 20004
`Telephone: (202) 508-8000
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`
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`2
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`
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`Facsimile: (202) 508-8100
`Jonathan.defosse@shearman.com
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`
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`3
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