`Filed on behalf of Intel Corporation
`By: Grant K. Rowan, Reg. No. 41,278
`Yung-Hoon Ha, Reg. No. 56,368
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: Grant.Rowan@wilmerhale.com
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` Yung-Hoon.Ha@wilmerhale.com
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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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`INTEL CORPORATION
`Petitioner
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`v.
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`DSS Technology Management, Inc.
`Patent Owner
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`Case IPR2016-00289
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`UPDATED DECLARATION OF LOUIS W. TOMPROS IN SUPPORT OF
`MOTION FOR ADMISSION PRO HAC VICE
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`Intel v. DSS
`IPR2016-00289
`Exhibit 1022
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`Case No. IPR2016-00289
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`I, Louis W. Tompros, declare as follows:
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`1.
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`I am a partner at the law firm of Wilmer Cutler Pickering Hale
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`and Dorr LLP in Boston, Massachusetts.
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`2.
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`I have been practicing law for more than twelve years. My
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`practice during that time has focused on intellectual property litigation, and
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`particularly, patent litigation.
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`3.
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`I am a member in good standing of the Bar of the
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`Commonwealth of Massachusetts, and am admitted to practice before the
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`United States Court of Appeals for the Federal Circuit, the United States
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`Supreme Court, the United States Court of Appeals for the First Circuit, the
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`United States Court of Appeals for the Seventh Circuit, and the United
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`States District Court for the District of Massachusetts.
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`4. My Massachusetts Bar membership No. is 657791.
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`5.
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`I have represented parties in patent litigation cases in the District of
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`Massachusetts, the Eastern District of Texas, the District of Delaware, the
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`Northern, Central, Eastern, and Southern Districts of California, the District of
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`Minnesota, and the International Trade Commission, among other jurisdictions.
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`Those cases have involved, among other issues, issues involving Patent Office
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`rules, regulations, and procedures, including inventorship disputes, inequitable
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`conduct, prosecution history disclaimer, and other issues for which review of a
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`Case No. IPR2016-00289
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`patent’s prosecution history is critical. See, e.g., General Electric Company v.
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`Wilkins, No 1:10-cv-00674-LJO-JLT (E.D. Cal.) (involving disputed inventorship);
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`Qualcomm, Inc. v. Broadcom Corporation, No. 3:05-cv-1958 (S.D. Cal.)
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`(involving allegations of inequitable conduct).
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`6.
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`I have represented parties in patent appeals to the United States Court
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`of Appeals for the Federal Circuit in twenty-nine cases. Two of those cases were
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`appeals from the Patent Trial and Appeal Board (“the Board”)—In re Thomas G.
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`Packard, No. 13-1204 (PTAB No. 12/004,324), and In re Klein, 647 F.3d 1343,
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`No. 2010-1411 (BPAI No. 10/2007,747). I was lead counsel in the Klein and
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`Packard cases.
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`7.
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`I have, on pro hac vice admission, represented parties in inter partes
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`reexamination matters before the Board in three matters, Reexam Control Nos.
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`95/000,580, 95/000,633, and 95/001,272.
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`8.
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`I have never been suspended, disbarred, sanctioned or cited for
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`contempt by any court or administrative body.
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`9.
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`On November 7, 2013, the Patent Office denied my petition to be
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`admitted pro hac vice as backup counsel in inter partes reexamination proceeding
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`Control No. 95/001,272. However, upon a petition for reconsideration, the Board
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`subsequently admitted me pro hac vice in those proceedings in its decision dated
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`December 12, 2013. In addition, on August 9, 2016, the Patent Office denied my
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`Case No. IPR2016-00289
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`motion to be admitted pro hac vice in this instant proceeding and Case Nos.
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`IPR2016-00287, IPR2016-00288 and IPR2016-00290 for inadvertently omitting
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`averments required by the ’639 Order, part 2(b), paragraphs ii and iv.
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`10.
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`I have read and will comply with Office Patent Trial Practice guide
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`and the Board’s Rules of Practice for Trials, as set forth in 37 C.F.R. Part 42.
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`11.
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`I agree to be subject to the United States Patent and Trademark Office
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`Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et. seq. and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`12.
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`In the past three years, I have appeared pro hac vice before the United
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`States Patent and Trademark Office in the following proceedings: Control Nos.
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`95/000,580, 95/000,633, and 95/001,272. Petitioner Intel Corp. has moved for my
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`admission pro hac vice in Case Nos. IPR2016-00287, IPR2016-00288, IPR2016-
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`00289 and IPR2016-00290 on March 25, 2016 ,which was denied as explained
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`above. Petitioner Intel Corp. has moved for my admission pro hac vice in Case
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`Nos. IPR2016-00287, IPR2016-00288 and IPR2016-00290 concurrently with this
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`motion.
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`13.
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`I am familiar with the subject matter at issue in this proceeding. I
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`participated in the drafting of the Petition filed in this proceeding, and I have
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`reviewed the papers filed in this proceeding.
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`Case No. IPR2016-00289
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`14.
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`I have represented Intel Corporation in multiple patent-related
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`matters, including the following United States District Court cases: DSS Tech.
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`Mgmt., Inc. v. Intel Corp. et al., 6:15-CV-130-JRG (E.D. Tex.), which is related to
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`and involves the same patent at issue in this proceeding; Power Management
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`Solutions LLC v. Intel Corporation et al, 1:11-cv-00743 (D. Del.); and Power
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`Management Solutions LLC v. Intel Corporation, 13-1457 (Fed. Cir.).
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`15.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true; and further that these statements are made with the knowledge
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`that willful false statements and the like are punishable by fine, imprisonment, or
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`both, under Section 1001 of Title 18 of the United States Code.
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`Respectfully Submitted,
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`___/Louis W. Tompros/____________
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`Louis W. Tompros
`WILMER CUTLER PICKERING
`HALE AND DORR LLP
`60 State Street
`Boston, MA 02109
`Louis.Tompros@wilmerhale.com
`Tel.: 617-526-6000
`Fax: 617-526-5000
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`August 10, 2016
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`5