`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
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`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
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`K.J. PRETECH CO., LTD.,
`Petitioner,
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`v.
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`INNOVATIVE DISPLAY TECHNOLOGIES LLC,
`Patent Owner.
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`Case IPR2015-01868
`U.S. Patent No. 7,434,974
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`PRO HAC VICE MOTION TO ADMIT ATTORNEY
`T. WILLIAM KENNEDY PURSUANT TO 37 C.F.R. § 42.10(c)
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`EXHIBIT 2010: DECLARATION OF T. WILLIAM KENNEDY
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
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`Case IPR2015-01868
`Patent 7,434,974
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`I, T. William Kennedy, make the following declaration based on my own
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`personal knowledge and, if called to testify before the court, could and would testify
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`as follows:
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`1.
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`I am an attorney with the law firm of Bragalone Conroy, P.C., located
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`2.
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`3.
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`at 2200 Ross Avenue, Suite 4500-West, Dallas, TX 75201.
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`I am a member in good standing of the Texas State Bar.
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`I have never been subject to any suspensions or disbarments from
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`practice before any court or administrative body.
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`4.
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`None of my applications for admission to practice before any court or
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`administrative body has ever been denied.
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`5.
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`I have never been sanctioned nor had contempt citations imposed by
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`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 Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of 37
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`C.F.R.
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`7.
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`I will be subject to the USPTO Rules of Professional Conduct set forth
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`in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37
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`C.F.R. § 11.19(a).
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`8.
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`During the past three years, I have applied to appear pro hac vice before
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`the PTAB in nine other proceedings, three of which have been granted,
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`Case IPR2015-01868
`Patent 7,434,974
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`two of which involved IPRs that were joined with those for which my
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`pro hac vice motion had been already granted, and the remainder of
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`which remain pending. All nine of the pro hac vice motions involve the
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`same or related patents as this proceeding and also involve the same or
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`similar subject matter:
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`i. IPR2014-01096 (granted);
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`ii. IPR2014-01097 (pending);
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`iii. IPR2014-01362 (pending);
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`iv. IPR2015-00487 (granted);
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`v. IPR2015-00506 (granted);
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`vi. IPR2015-01666 (joined with IPR2015-00506 above);
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`vii. IPR2015-01717 (joined with IPR2015-00487 above);
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`viii. IPR2015-01866 (pending, filed concurrently herewith); and
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`ix. IPR2015-01867 (pending, filed concurrently herewith).
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`I have not applied to appear pro hac vice in any other proceeding before
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`the PTAB.
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`9.
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`I currently represent the Patent Owner Innovative Technologies
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`Display LLC, in its assertion of the patent at issue in this proceeding
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`and its related patents in numerous cases resolved in the Eastern District
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`of Texas and pending in the District of Delaware. See, e.g., Delaware
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`Case IPR2015-01868
`Patent 7,434,974
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`Display Group LLC et al. v. LG Electronics, Inc. et al., No. 1:13-cv-
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`02109 (D. Del., filed Dec. 31, 2013); see also Delaware Display Group
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`LLC et al. v. VIZIO Inc., et al., No. 1:13-cv-02112 (D. Del., filed Dec.
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`31, 2013). As counsel in those actions, I have become very familiar the
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`subject matter at issue in this proceeding, i.e., light emitting panel
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`assemblies. Moreover, during the course of those lawsuits, I have
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`analyzed the prior art involved in this petition as it relates to the patent-
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`at-issue as well as its related patents, all of which concern light emitting
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`panel assemblies. Furthermore, in those lawsuits I have developed
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`infringement allegations that assert the patent-at-issue in this petition
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`against various light emitting panel assemblies, including those found
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`in smart phones, tablets, laptop computers, and televisions to name a
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`few. In my role as counsel in those litigations, I have spent significant
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`time learning the technology involved in light emitting panel
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`assemblies such as those found in the patent-at-issue in this proceeding.
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`As of this date, there are 60 total IPRs covering the patent-at-issue and
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`its related patents. I have reviewed and analyzed each of those matters.
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`Case IPR2015-01868
`Patent 7,434,974
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 15th day of December, 2016.
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`T. William Kennedy
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 West
`Dallas, TX 75201
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`5