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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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`APPLE INC.,
`Petitioner
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`v.
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`OpenTV, Inc.,
`Patent Owner.
`
`Case IPR2015-01031
`Patent 7,900,229
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`
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`DECLARATION OF MELODY DRUMMOND HANSEN IN SUPPORT OF
`PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION PURSUANT
`TO 37 C.F.R. §42.10(C)
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`APPLE 1020
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`IPR2015-01031
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`1.
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`I, Melody Drummond Hansen, declare as follows:
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`I am a Counsel with the law firm of O’Melveny & Myers LLP. I represent
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`and advise Petitioner Apple Inc. (“Apple”) in connection with the above-captioned
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`inter partes review (“IPR”) proceeding, and I am counsel in the co-pending district
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`court litigation (OpenTV, Inc. and Nagravision, SA v. Apple Inc., Case No. 3:14-
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`cv-01622-HSG (N.D. Cal.)) on the patent at issue in this IPR, U.S. Patent No.
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`7,900,229 (“’229 Patent”).
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`2.
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`I have been a member in good standing of the Bar of the State of California
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`since 2011. My California State Bar number is 278786. I am also admitted to
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`practice before other state and federal courts, including:
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`a. U.S. Court of Appeals, Federal Circuit (admitted September 2013);
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`b. U.S. Court of Appeals, Ninth Circuit (admitted April 2012);
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`c. U.S. District Court, California Central (admitted October 2012);
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`d. U.S. District Court, California Northern (admitted May 2012);
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`e. D.C. Court of Appeals (D.C. Bar) (admitted February 2008);
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`f. U.S. District Court, Illinois Northern (admitted January 2006); and
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`g. Illinois Supreme Court (Illinois Bar) (admitted November 2005).
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`3.
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`I have 10 years of experience practicing patent and technology-related
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`litigation. I have litigated patent cases across the country, including in California,
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`IPR2015-01031
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`Delaware, Virginia, Texas, and the International Trade Commission, and I have
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`litigated cases through trial and appeal.
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`4.
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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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`5.
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`I have never had an application for admission to practice before any court or
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`administrative body denied.
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`6.
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`I have not had a sanction or contempt citation imposed against me by any
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`court or administrative body.
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`7.
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`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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`8.
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`I agree to and will be subject to the USPTO Rules of Professional Conduct
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`set forth 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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`9.
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`I have not applied to appear pro hac vice before the Office in any other
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`proceeding in the last three years.
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`10.
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`I am familiar with the subject matter at issue in this proceeding. I have been
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`actively involved in the present IPR proceeding regarding the ’229 Patent. I
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`represent Petitioner in the co-pending district court litigation involving the ’229
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`Patent, and I have reviewed the patent, the Patent Owner’s infringement
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`IPR2015-01031
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`contentions served in the district court litigation, the parties’ claim construction
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`positions, and the prior art being asserted in this IPR proceeding.
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`11. Moreover, I have advised Petitioner on strategy regarding Petitioner’s
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`affirmative arguments in this IPR proceeding, reviewed the accompanying
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`Declaration of Dr. Knutson, and worked with Petitioner to find and identify the
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`references relied upon in the petition and to draft submissions to the Office.
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`12. The prior art reference at issue in the instituted IPR proceeding also is at
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`issue in the co-pending district court litigation. I have reviewed both that art and
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`other related prior art—all of which were disclosed in invalidity contentions that I
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`assisted with. I also have represented clients in connection with other patent
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`litigations regarding technology similar to that at issue in this IPR.
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`13.
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`I hereby declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true.
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`I further declare that these statements were made with the knowledge that willful
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`false statements and the like are punishable by fine or imprisonment, or both, under
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`Section 1001 of Title 18 of the United States Code.
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`Date: October 26, 2015
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`Respectfully submitted,
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`/s/ Melody Drummond Hansen
`Melody Drummond Hansen
`O’Melveny & Myers LLP
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`3
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`APPLE 1020
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