`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`
`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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`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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`DELAWARE DISPLAY GROUP LLC,
`Patent Owner.
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`
`
`Case IPR2015-00506
`U.S. Patent No. 7,434,973
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`
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`PRO HAC VICE MOTION TO ADMIT ATTORNEY T. WILLIAM
`KENNEDY PURSUANT TO 37 C.F.R. § 42.10(c)
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`EXHIBIT 2006: DECLARATION OF T. WILLIAM KENNEDY
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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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`
`
`Case IPR2015-00506
`Patent 7,434,973
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`I, T. William Kennedy, make the following declaration based on my own
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`personal knowledge and, if called to testify before the court, could and would testify
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`as follows:
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`1.
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`I am an attorney with the law firm of Bragalone Conroy, P.C., located
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`2.
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`3.
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`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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`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 Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of 37
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`C.F.R.
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`7.
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`I will be subject to the USPTO Rules of Professional Conduct set forth
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`in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37
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`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 before
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`the PTAB in five other proceedings, all pending. All five of the pro hac
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`2
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`
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`Case IPR2015-00506
`Patent 7,434,973
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`vice motions involve the same or related parties as this proceeding and
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`also involve the same or similar subject matter:
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`i. IPR2014-01096 (pending);
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`ii. IPR2014-01097 (pending);
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`iii. IPR2014-01362 (pending);
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`iv. IPR2015-00487 (pending); and
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`v. IPR2015-01717 (pending).
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`I have not applied to appear pro hac vice in any other proceeding before
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`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 the Patent Owner in its assertion of the patent at
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`issue in this proceeding and its related patents in numerous cases
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`resolved in the Eastern District of Texas and pending in the District of
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`Delaware. See, e.g., Delaware Display Group LLC et al. v. LG
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`Electronics, Inc. et al., No. 1:13-cv-02109 (D. Del., filed Dec. 31,
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`2013); see also Delaware Display Group LLC et al. v. Vizio Inc., et al.,
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`No. 1:13-cv-02112 (D. Del., filed Dec. 31, 2013). As counsel in those
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`actions, I have become very familiar the subject matter at issue in this
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`proceeding, i.e., light emitting panel assemblies. Moreover, during the
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`course of those lawsuits, I have analyzed the prior art involved in this
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`3
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`
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`Case IPR2015-00506
`Patent 7,434,973
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`petition as it relates to the patent-at-issue as well as its related patents,
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`all of which concern light emitting panel assemblies. Furthermore, in
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`those lawsuits I have developed infringement allegations that assert the
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`patent-at-issue in this petition against various light emitting panel
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`assemblies, including those found in smart phones, tablets, laptop
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`computers, and televisions to name a few. In my role as counsel in those
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`litigations, I have spent significant time learning the technology
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`involved in light emitting panel assemblies such as those found in the
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`patent-at-issue in this proceeding.
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`
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`I declare under penalty of perjury that the foregoing is true and correct.
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`
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`Executed this 9th day of September, 2015.
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`T. William Kennedy
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 West
`Dallas, TX 75201
`
`4
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