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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`______________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`______________________
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`GOOGLE INC.,
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`Petitioner
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`v.
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`AT HOME BONDHOLDERS’ LIQUIDATING TRUST
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`Patent Owner
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`______________________
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`Case IPR2015-No. 00660
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`U.S. Patent No. 6,286,045
`______________________
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`DECLARATION OF AUDREY MANESS IN SUPPORT OF
`MOTION TO APPEAR PRO HAC VICE ON BEHALF OF
`PATENT OWNER AT HOME BONDHOLDERS’ LIQUIDATING TRUST
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`Case IPR2015-00660
`Declaration of Audrey Maness
`In Support of Motion for Pro Hac Vice Admission
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`I, Audrey Maness, declare as follows:
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`1.
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`I am an experienced litigation attorney with more than eight
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`years of experience. I have been litigating patent cases for approximately seven
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`years.
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`2.
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`Lead counsel in this proceeding is Garland Stephens, who is
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`registered to practice before the United States Patent and Trademark Office and
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`holds Registration No. 37,242. Back up counsel is Justin Constant (Reg. No.
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`66,884). With respect to this proceeding, I will work closely with Mr. Stephens
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`and Mr. Constant.
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`3.
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`I am a member in good standing of the Texas State Bar and am
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`admitted to practice in the United States Court of Appeals for the Fifth, Eighth and
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`Federal Circuits, and the United States District Courts for the Eastern and Northern
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`Districts of Texas.
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`4.
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`I have never been suspended or disbarred from practice before
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`any court or administrative body.
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`5.
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`I have never had an application for admission to practice before
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`any court or administrative body denied.
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`6.
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` I have not had sanctions or contempt citations imposed against
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`me by any court or administrative body.
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`1
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`Case IPR2015-00660
`Declaration of Audrey Maness
`In Support of Motion for Pro Hac Vice Admission
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`7.
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`I am familiar with the subject matter at issue in this proceeding,
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`including the patent-at-issue, based on my work as lead counsel in the pending
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`district court case Richard A. Williamson, On Behalf of and as Trustee for At Home
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`Bondholders’ Liquidating Trust v. Google Inc., No. 3:15-cv-00966-JD (N.D. Cal.
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`March 3, 2015).
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`8.
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`I am actively involved in all aspects of the pending district
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`court case, which was originally filed in the District of Delaware (Case No. 1:14-
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`cv-00216-GMS) on February 19, 2014 before getting transferred to the Northern
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`District of California on March 2, 2015, including the issue of validity of the
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`patent-in-suit, which include the patent at issue in this proceeding. Patent Owner
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`also asserted the related U.S. Patent No. 6,014,698 in this litigation. In view of my
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`legal experience and familiarity with the issues in the present matter, Patent Owner
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`has requested my services in this proceeding. Denial of my appearance in this case
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`would create an undue burden for the Patent Owner.
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`9.
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`I have read and will comply with the Office Patent Trial
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`Practice Guide and the Board's Rules of Practice for Trials set forth in part 42 of
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`the C.F.R.
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`2
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`Declaration of Audrey Maness
`In Support of Motion for Pro Hac Vice Admission
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`Case IPR2015—O0660
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`10.
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`I agree to be subject
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`to the USPTO Code of Professional
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`Responsibility set
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`forth in 37 C.P.R. §§10.2O et seq., and to disciplinary
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`jurisdiction under 3 7 C.F.R. § 11.19( a).
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`11.
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`I have not applied to appear pro hac vice before this office
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`before.
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`Executed on June 26, 2015, at Houston, Texas.
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`I declare under penalty of perjury that the foregoing is true and correct.
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` udrey Maness
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`Case IPR2015-00660
`Declaration of Audrey Maness
`In Support of Motion for Pro Hac Vice Admission
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`CERTIFICATE OF SERVICE
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`I hereby certify that on June 26, 2015, a copy of the DECLARATION OF
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`JARED BOBROW IN SUPPORT OF MOTION TO APPEAR PRO HAC VICE
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`ON BEHALF OF PATENT OWNER AT HOME BONDHOLDERS’
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`LIQUIDATING TRUST was served by filing this document through the Patent
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`Review Processing System as well as delivering a copy via electronic mail to
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`counsel of record for Petitioner Google at the following addresses:
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`Michelle K. Holoubek (Reg. No. 54,179)
`mholoubek-PTAB@skgf.com
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`Michael V. Messinger (Reg. No. 37,575)
`Mikem-PTAB@skgf.com
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`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 New York Avenue, NW
`Washington, DC 20005
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` /s/ Justin L. Constant
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`Justin L. Constant
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`Reg. No. 66883
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`4