`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`
`LAM RESEARCH CORP.,
`Petitioner,
`
`v.
`
`DANIEL L. FLAMM,
`Patent Owner.
`___________________
`
`Case IPR2015-01767
`Patent No. 6,017,221
`___________________
`
`
`
`DECLARATION OF MORGAN CHU IN SUPPORT OF
`LAM RESEARCH CORP.'S
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION
`
`
`
`
`
`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`8687575.3 01
`
`
`
`
`
`
`LAM Ex 1014-p. 1
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Case IPR2015-01767
`Patent No. 6,017,221
`I, Morgan Chu, declare as follows:
`
`
`
`1.
`
`2.
`
`I am an attorney licensed to practice law in the state of California.
`
`I am a member in good standing of the Bar of the State of California.
`
`I am also admitted to practice before the United States Supreme
`
`Court, the United States Courts of Appeals for the Federal, Second,
`
`Fifth, Ninth, and Eleventh Circuits, and the United States District
`
`Courts for the Central District of California, Northern District of
`
`California, Southern District of California, Eastern District of
`
`California, United States District Court for District of Colorado,
`
`United States District Court for the Western District of Wisconsin,
`
`and United States District Court for the Eastern District of Texas.
`
`3.
`
`I am a member in good standing in all jurisdictions where I have been
`
`admitted to practice.
`
`4.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`5.
`
`I have never had an application denied for admission to practice
`
`before any court or administrative body.
`
`6.
`
`I have never had any sanctions or contempt citations imposed by any
`
`court or administrative body.
`
`8687575.3 01
`
`
`- 1 -
`
`
`
`LAM Ex 1014-p. 2
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Case IPR2015-01767
`Patent No. 6,017,221
`
`7.
`I have read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials set forth in part 42
`
`of the C.F.R.
`
`8.
`
`I agree to be subject to the USPTO Rules of Professional Conduct set
`
`forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under
`
`37 C.F.R. § 11.19(a).
`
`9.
`
`I have appeared Pro Hac Vice before the Patent Trial and Appeal
`
`Board in connection with IPR Nos. IPR2013-00004, IPR2013-00007,
`
`IPR2014-00727, IPR2014-01510, IPR2014-01511, IPR2014-01513
`
`and IPR2015-01719.
`
`10.
`
`I am a Partner at the law firm of Irell & Manella LLP. I have been
`
`litigating cases relating to patents for nearly forty (40) years,
`
`including cases involving co-pending proceedings in the United States
`
`Patent and Trademark Office.
`
`11.
`
`I have an established familiarity with the subject matter at issue in
`
`these proceedings. U.S. Patent No. 6,017,221 ("the '221patent") is
`
`assigned to Daniel Flamm and is at issue in a co-pending declaratory
`
`judgment litigation involving Petitioner Lam Research Corporation,
`
`Inc., Lam Research Corp. v Daniel L. Flamm, Civil Action No. 5:15-
`
`cv-01277-BLF (N.D. Cal.), and in the case Daniel L. Flamm v
`
`8687575.3 01
`
`
`- 2 -
`
`
`
`LAM Ex 1014-p. 3
`LAM v FLAMM
`IPR2015-01767
`
`
`
`Case IPR2015-01767
`Patent No. 6,017,221
`
`Samsung Electronics Co., Ltd, et al., Case 1:15-cv-613 (W.D. Tex.).
`
`I am counsel for the Petitioner, Lam Research Corporation, in the
`
`N.D. Cal. litigation. I have engaged closely in issues related to the
`
`'221 patent, including the preparation and filing of the complaint and
`
`the preparation and filing of motions in the underlying litigation. As a
`
`result, I have acquired substantial understanding of the underlying
`
`legal and technological issues at stake in these proceedings.
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true;
`
`and further that these statements are made with the 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 and that such willful false
`
`statements may jeopardize the validity of U.S. Patent No. 6,017,221.
`
`Date: May 9, 2016
`
`/Morgan Chu/
` Morgan Chu
`
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067-4276
`Telephone: (310) 277-1010
`Fax: (310) 203-7199
`Email: mchu@irell.com
`
`
`
`8687575.3 01
`
`
`- 3 -
`
`
`
`LAM Ex 1014-p. 4
`LAM v FLAMM
`IPR2015-01767
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