`LG Electronics U.S.A., Inc.
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`Paper __
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`Date filed: April14, 2016
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`By: Brian A. Tollefson, Lead Counsel
`Michael V. Battaglia, Back-up Counsel
`ROTHWELL, FIGG, ERNST & MANBECK, P.C.
`607 14th Street, N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`Emails: btollefson@rothwellfigg.com
`mbattaglia@rothwellfigg.com
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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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`LG ELECTRONICS, INC., and
`LG ELECTRONICS U.S.A., INC.,
`Petitioner
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`v.
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`TOSHIBA SAMSUNG STORAGE TECHNOLOGY KOREA CORPORATION,
`Patent Owner
`
`Case IPR2015-01653
`Patent RE43,106
`
`DECLARATION OF MICHAEL H. JONES IN SUPPORT OF
`PETITIONER'S MOTION FOR ADMISSION PRO HAC VICE
`
`
`
`Case IPR2015-01653
`Patent RE43,106
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`I, Michael H. Jones, declare as follows:
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`1.
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`I have been practicing in the field of intellectual property, and
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`particularly, patent litigation, for approximately six years.
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`2.
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`I am a member in good standing of the Bars of the District of
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`Columbia and the State of Virginia. I am admitted to practice in the United States
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`Court of Appeals for the Federal Circuit.
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`3.
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`I have been in private practice and litigating patent cases since 2010.
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`I also served as a summer law clerk working on various patent matters under the
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`supervision of attorneys in 2008 and 2009.
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`4.
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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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`5.
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`I have never had a court or administrative body deny my application
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`for admission to practice.
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`6.
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`No sanctions or contempt citations have ever been imposed against
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`me by any court or administrative body.
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`2
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`
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`Case IPR2015-01653
`Patent RE43,106
`I have read and will comply with the Office Patent Trial Practice
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`7.
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`Guide and the Board's Rules of Practice for Trials, as set forth in Part 42 of 37
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`C.P.R.
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`8.
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`I agree to be subject to the USPTO Rules of Professional Conduct set
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`forth in 37 C.P.R.§§ 11.101 et seq. and disciplinary jurisdiction under 37 C.P.R.
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`§ 11.19(a). I also agree to be subject to the USPTO 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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`9.
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`In the past three (3) years, I have not been admitted pro hac vice in
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`any proceedings before the United States Patent and Trademark Office.
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`10.
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`I am familiar with the subject matter at issue in this proceeding. I am
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`counsel in the LG Electronics, Inc. and LG Electronics U.S.A., Inc. v. Toshiba
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`Samsung Storage Technology Korea Corporation (Case No. 1:12-cv-01063-LPS-
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`CJB) and Toshiba Samsung Storage Technology Korea Corporation v. LG
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`Electronics, Inc., LG Electronics U.S.A., Inc. and LG International (America), Inc.
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`(Case No. 1:15-cv-00691-LPS-CJB), both patent infringement litigations, which
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`are pending in the United States District Court for Delaware and involve the patent
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`at issue in this proceeding.
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`3
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`
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`Case IPR2015-01653
`Patent RE43, 106
`I hereby declare that all statements made herein of my own
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`11.
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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 U.S. Patent
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`No. RE43,106.
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`Michael H. J n s
`ROTHWEL
`IGG, ERNST &
`MANBECK, P.C.
`607 14th St., N.W., Suite 800
`Washington, DC 20005
`Phone: 202-783-6040
`Facsimile: 202-783-6031
`Email: mjones@rothwellfigg.com
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`4
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`
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`CERTIFICATE OF SERVICE
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`Case IPR2015-01653
`Patent RE43,106
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`I hereby certify that on this 14th day of April, 2016, a true and correct copy
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`of the foregoing DECLARATION OF MICHAEL H. JONES IN SUPPORT OF
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`PETITIONER'S MOTION FOR ADMISSION PRO HAC VICE was served, via
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`electronic mail upon the following counsel for Patent Owner Toshiba Samsung
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`Storage Technology Korea Corporation:
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`Joseph A. Rhoa, Esq.
`Jonathan A. Roberts, Esq.
`Nixon & Vanderhye P.C.
`901 North Glebe Road, 11th Floor
`Arlington, VA 22203-1808
`Phone: 703-816-4000
`Facsimile: 703-816-4100
`Emails: jar@nixonvan.com
`jr@nixonvan.com
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`I Erik van Leeuwen I
`Erik van Leeuwen
`Litigation Operations Coordinator
`Rothwell, Figg, Ernst & Manbeck, P.C.
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`5