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Filed on behalf of Innovative Display Technologies LLC.
`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`Tel: 214.785.6670
`Fax: 214.786.6680
`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`K.J. PRETECH CO., LTD.,
`Petitioner,
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC,
`Patent Owner.
`
`
`
`Case IPR2015-01867
`U.S. Patent No. 7,537,370
`
`
`
`PRO HAC VICE MOTION TO ADMIT ATTORNEY JEFFREY R.
`BRAGALONE PURSUANT TO 37 C.F.R. § 42.10(c)
`
`EXHIBIT 2010: DECLARATION OF JEFFREY R. BRAGALONE
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`
`

`
`Case IPR2015-01867
`Patent 7,537,370
`
`I, Jeffrey R. Bragalone, make the following declaration based on my own
`
`personal knowledge and, if called to testify before the court, could and would testify
`
`as follows:
`
`1.
`
`I am a shareholder with the law firm of Bragalone Conroy, P.C., located
`
`2.
`
`3.
`
`at 2200 Ross Avenue, Suite 4500-West, Dallas, TX 75201.
`
`I am a member in good standing of the Texas State Bar.
`
`I have never been subject to any suspensions or disbarments from
`
`practice before any court or administrative body.
`
`4.
`
`None of my applications for admission to practice before any court or
`
`administrative body has ever been denied.
`
`5.
`
`I have never been sanctioned nor had contempt citations imposed by
`
`any court or administrative body.
`
`6.
`
`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 37
`
`C.F.R.
`
`7.
`
`I will 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).
`
`8.
`
`During the past three years, I have applied to appear pro hac vice before
`
`the PTAB in twenty-five other proceedings, twenty-one of which have
`
`
`
`2
`
`

`
`Case IPR2015-01867
`Patent 7,537,370
`
`been granted, two of which involved IPRs that were joined with those
`
`for which my pro hac vice motion had been already granted, and the
`
`remainder of which remain pending. Fourteen of the pro hac vice
`
`motions involve the same or related patents as this proceeding and also
`
`involve the same or similar subject matter:
`
`i. IPR2014-01092 (granted);
`
`ii. IPR2014-01094 (granted);
`
`iii. IPR2014-01095 (granted);
`
`iv. IPR2014-01096 (granted);
`
`v. IPR2014-01097 (granted);
`
`vi. IPR2014-01357 (granted);
`
`vii. IPR2014-01359 (granted);
`
`viii. IPR2014-01362 (granted);
`
`ix. IPR2015-00487 (granted);
`
`x. IPR2015-00506 (granted);
`
`xi. IPR2015-01666 (joined with IPR2015-00506 above);
`
`xii. IPR2015-01717 (joined with IPR2015-00487 above);
`
`xiii. IPR2015-01866 (pending, filed concurrently herewith); and
`
`xiv. IPR2015-01868 (pending, filed concurrently herewith).
`
`
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`3
`
`

`
`Case IPR2015-01867
`Patent 7,537,370
`
`The remaining eleven pro hac vice motions involve eleven other IPRs
`
`all unrelated to this petition:
`
`xv. CBM2014-00166 (granted);
`
`xvi. IPR2014-00785 (granted);
`
`xvii. IPR2014-00810 (granted);
`
`xviii. IPR2014-00824 (granted);
`
`xix. IPR2014-00825 (granted);
`
`xx. IPR2014-01278 (granted);
`
`xxi. IPR2014-01282 (granted);
`
`xxii. IPR2014-01283 (granted);
`
`xxiii. IPR2015-00153 (granted);
`
`xxiv. IPR2015-00155 (granted); and
`
`xxv. IPR2015-00156 (granted).
`
`I have not applied to appear pro hac vice in any other proceeding before
`
`the PTAB.
`
`9.
`
`I have familiarity with the subject matter at issue in this proceeding. I
`
`currently represent Patent Owner Innovative Display Technologies
`
`LLC, in its assertion of U.S. Patent No. 7,537,370 (the patent at issue-
`
`in this petition) and its related patents in numerous cases resolved in the
`
`Eastern District of Texas and pending in the District of Delaware. See,
`
`
`
`4
`
`

`
`Case IPR2015-01867
`Patent 7,537,370
`
`e.g., Delaware Display Group LLC et al. v. LG Electronics, Inc. et al.,
`
`No. 1:13-cv-02109 (D. Del., filed Dec. 31, 2013); see also Delaware
`
`Display Group LLC et al. v. Vizio Inc., et al., No. 1:13-cv-02112 (D.
`
`Del., filed Dec. 31, 2013). As lead counsel in those actions, I have
`
`familiarized myself with the subject matter at issue in this proceeding,
`
`i.e., light emitting panel assemblies. During the course of those
`
`lawsuits, I have developed invalidity defenses for the patent-at-issue in
`
`this petition as well as its related patents, all of which concern light
`
`emitting panel assemblies. Also in those lawsuits, I have developed
`
`infringement allegations that assert the patent-at-issue in this petition
`
`against various light emitting panel assemblies, including those found
`
`in smart phones, tablets, laptop computers, and televisions to name a
`
`few. In my role as the lead attorney in those litigations, I have spent
`
`significant time learning the technology involved in light emitting panel
`
`assemblies such as those found in the patent-at-issue in this proceeding.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Executed this 15th day of December, 2016.
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`5
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`Jeffrey R. Bragalone
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 West
`Dallas, TX 75201

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