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`MOTION FOR PRO HAC VICE ADMISSION
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`I, Victor G. Hardy, being duly sworn and upon oath, hereby attest to the
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`following:
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`1.
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`I am a member in good standing of the Bar of the State of Texas, Bar
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`of the State of New York, U.S. District Court for the Southern District of New
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`York, Eastern District of New York, and Southern District of Texas.
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`2.
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`I have not been suspended or disbarred from practice before any court
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`or administrative body.
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`3.
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`I have never had an application for admission to practice before any
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`court or administrative body denied.
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`4.
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`No sanction or contempt citation has been imposed against me by any
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`court or administrative body.
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`5.
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`I have read and will comply with the United States Patent and
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`Trademark Office (“Office”) Patent Trial Practice Guide and the Patent Trial and
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`Appeal Board (“Board”) Rules of Practice for Trials set forth in part 42 of 37
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`C.F.R.
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`6.
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`I agree to be subject to the Office’s Rules of Professional Conduct set
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`forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. §
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`11.19(a). I also agree to be subject to the Office’s Rules of Professional Conduct
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`as set forth in Changes to Representation of Others Before the United States Patent
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`and Trademark Office; Final Rule, 78 Fed. Reg. 20180 (Apr. 3, 2013) (effective
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`May 3, 2013).
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`7.
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`In the last three (3) years, I have applied to appear pro hac vice on
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`behalf of Patent Owner Software Rights Archive, LLC in IPR2013-00478,
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`IPR2013-00479, IPR2013-00480, and IPR2013-00481.
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`8.
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`I am an experienced litigation attorney, with experience with complex
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`litigation in both state and federal court. I am familiar with the subject matter at
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`issue in this proceeding, including the prior art on which the Petitioners rely and
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`U.S. Patent Nos. 6,199,076 (“the ‘076 Patent”) and 7,509,178 (“the ‘178 Patent”).
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`I have also reviewed the pertinent issues of claim construction that have been
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`briefed in this proceeding.
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`9.
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`I have represented Patent Owner Personal Audio LLC in the civil
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`action Personal Audio LLC v. Acer Inc., et al., 1:14-cv-0008 (E.D. Tex.) in which
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`the ‘076 and ‘178 Patents have been asserted.
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`10.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements are made with the knowledge
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`that willful false statements and the like so made are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States Code
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`and that such willful false statements may jeopardize the validity of the ‘076 and
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`/s/ Victor Hardy___________
`Victor Hardy
`DINOVO PRICE ELLWANGER &
`HARDY LLP
`7000 North MoPac Expressway
`Suite 350
`Austin, Texas 78731
`Tel: 214-948-3334
`Fax: 214-853-9410
`Email: vhardy@dpelaw.com
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`‘178 Patents.
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`Date: November 18, 2015
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