`_____________
`
`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 IPR2016-00127
`Patent 8,969,841
`_____________
`
`
`
`
`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 JINNIE L. REED
`IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
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`
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`Energetiq
`Exhibit 2102, Page 1
`Case IPR2016-00127
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`I, Jinnie L. Reed, declare as follows:
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`1.
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`I am an attorney licensed to practice law in the Commonwealth of
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`Massachusetts. I am also admitted to practice before the U.S. District Court for
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`the District of Massachusetts.
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`2.
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`I am a member in good standing of the Bar of the Commonwealth of
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`Massachusetts.
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`3.
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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 2102, Page 2
`Case IPR2016-00127
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`8.
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`I currently appear pro hac vice as back-up counsel in the following
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`proceedings before the United States Patent and Trademark Office: IPR2015-
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`01277, -01279, -01300, -01303, -01362, -01368, -01375, and -01377. I am
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`applying to appear pro hac vice before the United States Patent and Trademark
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`Office in the following proceeding: IPR2016-00126. Each of these proceedings
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`is related to this matter, as indicated in the Patent Owner’s Mandatory Notices.
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`IPR2016-00127, Paper 6.
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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 2011.
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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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`including actions concerning lithium batteries, data and telephony
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`communication in cable networks, mechanical devices, mobile devices, and
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`consumer electronics, among other technologies.
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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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`IPR2016-00127. 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, including U.S. Patent No.
`Energetiq
`Exhibit 2102, Page 3
`Case IPR2016-00127
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`8,969,841, which is the patent at issue in this IPR. For example, I represent
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`Energetiq before the International Trade Commission in the Matter of Certain
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`Laser-Driven Light Sources, Subsystems Containing Laser-Driven Light
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`Sources, and Products Containing Same, Docket No. 3107, (the “ITC matter”)
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`filed on December 15, 2015, which involves the patent at issue in this IPR. I
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`have been involved in preparing Energetiq’s patent infringement arguments and
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`patent validity arguments, including such arguments as they relate to U.S.
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`Patent No. 8,969,841, in the ITC matter.
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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. My knowledge of
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`this technology has been enhanced by my educational background: in addition
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`to holding a juris doctor degree, I hold a Bachelor of Science degree in
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`electrical engineering.
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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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`Energetiq
`Exhibit 2102, Page 4
`Case IPR2016-00127
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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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`Jinnie L. Reed, Esq.
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`
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`Executed on February 8, 2016
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`
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`PROSKAUER ROSE LLP
`One International Place
`Boston, Massachusetts 02110
`jreed@proskauer.com
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`Energetiq
`Exhibit 2102, Page 5
`Case IPR2016-00127
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`54410793v1