UNITED STATES PATENT AND TRADEMARK OFFICE
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`SL CORPORATION,
`Petitioner,
`
`v.
`
`ADAPTIVE HEADLAMP TECHNOLOGIES, INC.
`Patent Owner
`________________
`
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,241,034
`
`Issue Date: July 10, 2007
`
`Reexamination Certificate Issue Date: June 14, 2013
`
`Title: Automatic Directional Control System for Vehicle Headlights
`
`________________
`
`Inter Partes Review No. IPR2016-00193
`
`DECLARATION OF ADAM P. SAMANSKY
`
`Page 1 of 5
`SL Corporation v. Adaptive Headlamp
`
` Technologies, Inc.
`
` SL Corporation Exhibit 1028
` Case IPR2016-00193
`
`
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`SL CORPORATION,
`Petitioner,
`
`v.
`
`ADAPTIVE HEADLAMP TECHNOLOGIES, INC.
`Patent Owner
`________________
`
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,241,034
`
`Issue Date: July 10, 2007
`
`Reexamination Certificate Issue Date: June 14, 2013
`
`Title: Automatic Directional Control System for Vehicle Headlights
`
`________________
`
`Inter Partes Review No. IPR2016-00193
`
`DECLARATION OF ADAM P. SAMANSKY
`
`Page 1 of 5
`SL Corporation v. Adaptive Headlamp
`
` Technologies, Inc.
`
` SL Corporation Exhibit 1028
` Case IPR2016-00193
`
`
`
`I, Adam P. Samansky, do hereby declare:
`
`1.
`
`I am a member in the law firm of Mintz, Levin, Cohn, Ferris, Glovsky
`
`and Popeo P.C. (“Mintz Levin”). Current lead counsel in this inter partes review
`
`proceeding is Peter Cuomo, who is Of Counsel and is registered to practice before
`
`the United States Patent and Trademark Office and holds Registration No. 54,481.
`
`The back-up counsel Kongsik Kim and Serge Subach are also registered to practice
`
`before the United States Patent and Trademark Office and hold Registration Nos.
`
`63,867 and 74,652, respectively. During this proceeding, I will work closely with
`
`Mr. Cuomo and back-up counsel.
`
`2.
`
`I am a member in good standing of the Bar of the Commonwealth of
`
`Massachusetts and the State of New York. My Massachusetts Bar membership is
`
`661123. My New York Bar membership is 493582. I am admitted to practice
`
`before the Supreme Court of the United States, the United States Court of Appeals
`
`for the Federal Circuit, United States Court of Appeals for the First Circuit, United
`
`States District Court for the District of Columbia, United States District Court for
`
`the District of Massachusetts, United States District Court for the Eastern District
`
`of New York, United States District Court for the Southern District of New York,
`
`and the United States District Court for the Eastern District of Texas.
`
`2
`
`Page 2 of 5
`SL Corporation v. Adaptive Headlamp
`
` Technologies, Inc.
`
` SL Corporation Exhibit 1028
` Case IPR2016-00193
`
`
`
`3.
`
`I am admitted, pro hac vice, and am lead trial counsel in the
`
`underlying litigation before the U.S. District Court for the District of Delaware,
`
`Case No. 1:15-cv-0565.
`
`4.
`
`In addition, my 12 years of litigation practice I currently represent or
`
`have represented clients in numerous, electrical, mechanical and chemical, patent
`
`litigation cases in various United States courts. Those actions include among
`
`others:
`
`Inline Plastics Corp. v. EasyPak, LLC, Appeal No. 14-1305 (Fed. Cir.)
`
` MeadWestvaco v. Rexam, Appeal No. 12-1518 (Fed. Cir.)
` UbiComm v. Bulbs.com, 1;13-cv-00872-RGA (D. Del.)
` Dallakian v. IPG Photonics, 3:14-cv-11863-TSH (D. Mass.)
`Select Retrieval v. Bulbs.com, 4:12-cv-10389-TSH (D. Mass.)
`
`Samson Manufacturing v. Austin Precision Products, 1:09-cv-30027 (D. Mass.)
`
`Superior Shooting Systems v. Cole, 3:10-cv-01226 (N.D. Tex)
`
` Mitsubishi Chem. Co. v. Barr Labs., Inc., 718 F. Supp. 2d 382 (S.D.N.Y. 2010), aff’d,
`435 Fed. Appx. 927 (Fed. Cir. Aug. 2, 2011)
` Wellman, Inc., v. Eastman Chem. Co., 642 F.3d 1355 (2011), reh’g and reh’g en banc
`denied (Aug. 11, 2011), cert. denied, 132 S. Ct. 1541 (2012)
`Takeda Chem. Indus., Ltd. v. Alphapharm Pty., Ltd., 492 F.3d 1350 (Fed. Cir. 2007), cert.
`denied, 552 U.S. 1295 (2008)
`Takeda Chem. Indus., Ltd. v. Mylan Labs. Inc., 417 F. Supp. 2d 341 (S.D.N.Y. 2006)
`Takeda Chem. Indus., Ltd. v. Mylan Labs., Inc., 549 F.3d 1381 (Fed. Cir. 2008), cert.
`denied, 552 U.S. 1295 (2009)
`
`
`
`
`
`
`5.
`
`In addition to my J.D. obtained from Suffolk University, I hold a B.S.
`
`in Politics from Brandeis University. Accordingly, I am comfortable and
`
`experienced with technically and legally complex matters such as those raised in
`
`this inter partes review proceeding. In particular, I am experienced with
`
`3
`
`Page 3 of 5
`SL Corporation v. Adaptive Headlamp
`
` Technologies, Inc.
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` SL Corporation Exhibit 1028
` Case IPR2016-00193
`
`
`
`technically and legally complex matters in the fields of electrical and mechanical
`
`engineering.
`
`6.
`
`I am familiar with U.S. Patent No. 7,241,034 (“the ‘034 patent”), its
`
`prosecution history, and the legal subject matter, technical subject matter, and prior
`
`art discussed in Petitioner’s request for inter partes review of the ‘034 patent.
`
`7.
`
`I was substantially involved with the preparation of the Petition filed
`
`in this proceeding. In particular, I have worked with former lead counsel David
`
`Cotta and pending replacement lead counsel Peter Cuomo on scientific and
`
`strategic matters pertaining to the instant Petition and now-instituted IPR
`
`proceeding. As a result, I anticipate being significantly involved in the deposition
`
`and trial phase of this proceeding.
`
`8.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body, nor has a court or administrative body denied my
`
`application for admission to practice. I have not been sanctioned or cited for
`
`contempt by any court or administrative body.
`
`9.
`
`I have read and will comply with the Patent Office Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials set forth in Part 42 of 37 C.F.R.
`
`10.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`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).
`
`4
`
`Page 4 of 5
`SL Corporation v. Adaptive Headlamp
`
` Technologies, Inc.
`
` SL Corporation Exhibit 1028
` Case IPR2016-00193
`
`
`
`11. I 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 are punishable by fine, imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
` Respectfully bm tted,
`
`Adam P. Sarnansky
`MINTZ, LEVIN, COHN, FERRIS,
`GLOVSKY AND POPEO P.C.
`One Financial Center
`Boston, MA 02111
`(617) 542-6000
`
`Dated: June 24, 2016
`
`49654654v.1
`
`5
`
`Page 5 of 5
`SL Corporation v. Adaptive Headlamp
`
` Technologies, Inc.
`
` SL Corporation Exhibit 1028
` Case IPR2016-00193
`
`
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