UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`
`
`ASML NETHERLANDS B.V., EXCELITAS TECHNOLOGIES CORP., AND QIOPTIQ
`PHOTONICS GMBH & CO. KG,
`Petitioners,
`
`v.
`
`
`
`ENERGETIQ TECHNOLOGY, INC.,
`Patent Owner.
`_____________
`
`Case IPR2015-01303
`Patent 7,435,982
`_____________
`
`
`
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
`
`
`DECLARATION OF SAFRAZ W. ISHMAEL
`IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
`
`
`
`Energetiq
`Exhibit 2001, Page 1
`Case IPR2015-01303
`
`
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`
`
`ASML NETHERLANDS B.V., EXCELITAS TECHNOLOGIES CORP., AND QIOPTIQ
`PHOTONICS GMBH & CO. KG,
`Petitioners,
`
`v.
`
`
`
`ENERGETIQ TECHNOLOGY, INC.,
`Patent Owner.
`_____________
`
`Case IPR2015-01303
`Patent 7,435,982
`_____________
`
`
`
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
`
`
`DECLARATION OF SAFRAZ W. ISHMAEL
`IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
`
`
`
`Energetiq
`Exhibit 2001, Page 1
`Case IPR2015-01303
`
`
`
`I, Safraz W. Ishmael, declare as follows:
`
`1.
`
`I am an attorney licensed to practice law in the Commonwealth of
`
`Massachusetts. I am also admitted to practice before the U.S. District Court for
`
`the District of Massachusetts, the Eastern District of Texas, and the Western
`
`District of Wisconsin, as well as in the U.S. Court of Appeals for the First and
`
`Federal Circuits.
`
`2.
`
`I am a member in good standing of the Bar of the Commonwealth of
`
`Massachusetts.
`
`3.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`4.
`
`I have never been denied admission to practice before any court or
`
`administrative body.
`
`5.
`
`I have never been subject to sanctions or contempt citations imposed
`
`by any court or administrative body.
`
`6.
`
`I have read and will comply with Office Patent Trial Practice Guide
`
`and the Board’s Rules of Practice for Trials, as set forth in title 37, part 42 of
`
`the Code of Federal Regulations (C.F.R.).
`
`Energetiq
`Exhibit 2001, Page 2
`Case IPR2015-01303
`
`
`
`
`
`7.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`Rules of Professional Responsibility set forth in parts 10 and 11 of 37 C.F.R.
`
`and to disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`8.
`
`I have not appeared pro hac vice in any proceedings before the United
`
`States Patent and Trademark Office in the past three (3) years.
`
`9.
`
`I am Senior Counsel at the law firm of Proskauer Rose LLP
`
`(“Proskauer”). I joined Proskauer as an associate in 2011. I previously
`
`practiced law as an attorney at the law firms of Testa, Hurwitz & Thibeault LLP
`
`from 2003 – 2005 and at Goodwin Procter LLP from 2005 – 2011.
`
`10.
`
`I am an experienced litigating attorney and have specific experience in
`
`patent law and patent law litigation. I have represented clients in numerous
`
`patent infringement actions across the country in various technical fields,
`
`including actions concerning optical transmitter devices, applied physics
`
`devices, semiconductor manufacturing devices, mechanical devices, electronics,
`
`and computer software, among other technologies.
`
`11.
`
`I have an established familiarity with the subject matter at issue in
`
`IPR2015-01303. Specifically, I have reviewed the challenged patent, the
`
`Petition, and the accompanying exhibits. I represent Energetiq Technology,
`
`Inc. (“Energetiq”) in matters relating to its patents, including U.S. Patent No.
`Energetiq
`Exhibit 2001, Page 3
`Case IPR2015-01303
`
`
`
`
`
`7,435,982, which is the patent at issue in this IPR. For example, I represent
`
`Energetiq in Energetiq Technology, Inc. v. ASML Netherlands B.V., Excelitas
`
`Technologies Corp. and Qioptiq Photonics GMBH & Co. KG, 1:15-cv-10240-
`
`LTS, (the, “Litigation”) filed on January 30, 2015 and pending in the U.S.
`
`District Court for the District of Massachusetts, which involves the patent at
`
`issue in this IPR. I have been involved in preparing Energetiq’s patent
`
`infringement arguments and patent validity arguments, including such
`
`arguments as they relate to U.S. Patent No. 7,435,982, in the Litigation. I have
`
`been involved in the preliminary injunction proceedings in the Litigation, and
`
`as a result, I have reviewed and am familiar with the invalidity positions and
`
`prior art raised therein, and raised in this proceeding.
`
`12. Through my representation of Energetiq for at least over the last six
`
`months, and by working with Energetiq during that time to understand the
`
`technologies at issue, I have acquired substantial understanding of the
`
`technology at issue in this IPR, which pertains to laser-driven light sources and
`
`applied physics. My knowledge of this technology has been enhanced by my
`
`educational background: in addition to holding a juris doctor degree, I hold
`
`bachelor of science degrees in physics and computer science, and a master of
`
`science degree in physics.
`
`Energetiq
`Exhibit 2001, Page 4
`Case IPR2015-01303
`
`
`
`
`
`13.
`
`I declare that all statements made herein of my knowledge are true
`
`and that all statements made on information and belief are believed to be true;
`
`and further that these statements were made with full knowledge that willful
`
`false statements and the like so made are punishable by fine or imprisonment,
`
`or both, under Section 1001 of Title 18 of the United States Code.
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`Proskauer Rose LLP
`
`/ Safraz W. Ishmael /
` Safraz W. Ishmael, Esq.
`
`Energetiq
`Exhibit 2001, Page 5
`Case IPR2015-01303
`
`
`
`
`Executed on July 9, 2015
`
`
`
`
`
`PROSKAUER ROSE LLP
`One International Place
`Boston, Massachusetts 02110
`sishmael@proskauer.com
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