`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
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`LOWER DRUG PRICES FOR CONSUMERS, LLC
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`PETITIONER
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`V.
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`FOREST LABORATORIES HOLDINGS LIMITED
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`PATENT OWNER
`
`___________________
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`CASE NO.: IPR2016-00379
`PATENT NO. 6,545,040
`FILED: JANUARY 24, 1992
`ISSUED: 4/8/2003
`INVENTORS: XHONNEUX AND VAN LOMMEN
`TITLE: METHOD OF LOWERING THE BLOOD PRESSURE
`_______________
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`DECLARATION OF DONALD PUCKETT IN SUPPORT OF UNOPPOSED
`MOTION FOR PRO HAC VICE ADMISSION
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`1
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`LOWER DRUG PRICES FOR CONSUMERS, LLC
`Exhibit 1054
`IPR2016‐00379
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`
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`I, Donald Puckett, declare as follows:
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`1. I am more than twenty-one years of age, am competent to present this
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`declaration, and have personal knowledge of the facts set forth herein.
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`2. I have been practicing law in the field of intellectual property, and
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`specifically patent litigation, for more than fifteen years. I am also an Adjunct
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`Professor at Texas A&M School of Law where I have taught classes related to
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`patent litigation practice.
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`3. I have extensive experience litigating patent infringement cases in many
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`different district courts across the United States. My experience in patent litigation
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`matters includes, but is not limited to: presenting oral arguments to the Board in
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`IPR proceedings; serving as lead trial counsel in district court patent litigation;
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`presenting oral arguments to the court in claim construction hearings and other
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`patent-related hearings; taking depositions of expert witnesses regarding invalidity,
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`infringement, cand claim construction; drafting claim construction briefs; drafting
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`briefs associated with motions for summary judgments regarding invalidity and
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`infringement issues; drafting invalidity and infringement contentions; and handling
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`patent appeals before the United States Court of Appeals for the Federal Circuit.
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`4. I am a member in good standing of the State Bar of Texas. I am also
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`admitted to practice before the U.S. Court of Appeals for the Federal Circuit, the
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`2
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`LOWER DRUG PRICES FOR CONSUMERS, LLC
`Exhibit 1054
`IPR2016‐00379
`
`
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`United States District Court for the Eastern District of Texas, and the United States
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`District Court for the Northern District of Texas, among other courts.
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`5. I have never been suspended or disbarred from practice before any court
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`or administrative body. I have never been the subject of any ethical grievance
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`procedure or investigation.
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`6. No court or administrative body has ever denied my application for
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`admission to practice before it.
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`7. I have never had any sanctions or contempt citations imposed against me
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`by any court or administrative body.
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`8. 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 Title 37 of the
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`C.F.R.
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`9. I agree to be subject to the USPTO Rules of Professional Conduct as set
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`forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. §
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`11.19(a).
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`10. I have appeared before the Board pro hac vice in the last three years in
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`years in: (1) IPR2014-00411 and IPR2015-00065 (consolidated), and (2) IPR2014-
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`01431 and IPR2014-01432 (consolidated). I presented oral arguments to the Board
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`in both of these consolidated cases. See IPR2014-00411 at Paper No. 112;
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`IPR2014-01431 at Paper No. 47.
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`3
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`LOWER DRUG PRICES FOR CONSUMERS, LLC
`Exhibit 1054
`IPR2016‐00379
`
`
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`11. I have an established familiarity with the subject matter at issue in this
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`proceeding. I personally played a lead role in drafting the Petition for Inter Partes
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`Review filed in this matter on behalf of Petitioner Lower Drug Prices for
`
`Consumers, LLC. I have substantively reviewed all materials filed in this Inter
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`Partes Review, including the Petition for Inter Partes Review and all
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`accompanying exhibits (1001-1053). I am thus very familiar with the subject
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`matter in this proceeding.
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`12. I declare under penalty of perjury that the foregoing is true and correct.
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`Respectfully submitted,
`
`__________________
`Donald Puckett
`Nelson Bumgardner, P.C.
`3131 W. 7th Street
`Suite 300
`Fort Worth, Texas 76107
`P: 817.377.9111
`F: 817.377.3485
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`January 20, 2015
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`4
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`LOWER DRUG PRICES FOR CONSUMERS, LLC
`Exhibit 1054
`IPR2016‐00379
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