`_____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
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`ASML NETHERLANDS B.V., EXCELITAS TECHNOLOGIES CORP., AND
`QIOPTIQ PHOTONICS GMBH & CO. KG,
`Petitioner,
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`v.
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`ENERGETIQ TECHNOLOGY, INC.,
`Patent Owner.
`_____________
`
`Case IPR2015-01377
`Patent 7,435,982
`_____________
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`
`
`MAIL STOP PATENT BOARD
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`Post Office Box 1450
`Alexandria, Virginia 22313-1450
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`DECLARATION OF FABIO E. TARUD
`IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
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`Energetiq
`Exhibit 2203, Page 1
`Case IPR2015-01377
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`I, Fabio E. Tarud, declare as follows:
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`1.
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`I am an attorney licensed to practice law in the state of New York. I
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`am also admitted to practice before the U.S. District Court for the Eastern
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`District of New York and the United States Court of Appeals for the Federal
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`Circuit.
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`2.
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`3.
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`I am a member in good standing of the Bar of the State of New York.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
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`4.
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`I have never been denied admission to practice before any court or
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`administrative body.
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`5.
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`I have never been subject to sanctions or contempt citations imposed
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`by 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
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`Guide and the Board’s Rules of Practice for Trials, as set forth in title 37, part
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`42 of the Code of Federal Regulations (C.F.R.).
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`7.
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`I agree to be subject to the United States Patent and Trademark Office
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`Rules of Professional Responsibility set forth in part 11 of 37 C.F.R. and to
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`Energetiq
`Exhibit 2203, Page 2
`Case IPR2015-01377
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`8.
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`I am applying to appear pro hac vice before the United States Patent
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`and Trademark Office in the following proceedings: IPR2015-01277, -01279, -
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`01300, -01303, -01362, -01368, -01375, and -01377, as well as IPR2016-00126
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`and -00127. Each of these proceedings is related to this matter, as indicated in
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`the Patent Owner’s Mandatory Notices. IPR2015-01377, Papers 7, 10 and 19.
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`I was previously admitted pro hac vice in the following unrelated matters:
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`IPR2015-00570, -00571, -00572, and -00573.
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`9.
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`I am an associate at the law firm of Proskauer Rose LLP
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`(“Proskauer”). I joined Proskauer as an associate in November 2010.
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`10.
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`I am an experienced litigating attorney and have specific experience in
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`patent law and patent law litigation. I have represented clients in numerous
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`patent infringement actions across the country in various technical fields
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`relating to mechanical engineering, electrical engineering, and computer
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`science.
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`11.
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`I have an established familiarity with the subject matter at issue in
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`IPR2015-01377. Specifically, I have reviewed the challenged patent, the
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`Petition, and the accompanying exhibits. I represent Energetiq Technology,
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`Inc. (“Energetiq”) in matters relating to its patents. Furthermore, I am familiar
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`Energetiq
`Exhibit 2203, Page 3
`Case IPR2015-01377
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`with the subject matter and technology at issue in this IPR based on my
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`interactions with the listed inventor regarding the subject matter of this patent.
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`12. Through my representation of Energetiq and by working with
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`Energetiq during that time to understand the technologies at issue, I have
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`acquired substantial understanding of the technology at issue in this IPR, which
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`pertains to laser-driven light sources and applied physics.
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`13.
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`I declare that all statements made herein are true and that all
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`statements made on information and belief are believed to be true; and further
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`that these statements were made with full knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or
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`both, under Section 1001 of Title 18 of the United States Code.
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`Respectfully submitted,
`Proskauer Rose LLP
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` /
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` Fabio E. Tarud /
`Fabio Tarud, Esq.
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`Energetiq
`Exhibit 2203, Page 4
`Case IPR2015-01377
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`Executed on April 4, 2016
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`PROSKAUER ROSE LLP
`Eleven Times Square
`New York, NY 10036
`ftarud@proskauer.com