`
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`IPR2016-00418
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`
`
`PATENT NO. 8,155,342
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`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`TOYOTA MOTOR CORPORATION
`Petitioner
`v.
`
`BLITZSAFE TEXAS, LLC
`Patent Owner
`
`
`
`Patent No. 8,155,342
`Issue Date: April 10, 2012
`Title: MULTIMEDIA DEVICE INTEGRATION SYSTEM
`__________________________________________________________________
`
`DECLARATION OF ALFRED R. FABRICANT IN SUPPORT OF
`BLITZSAFE TEXAS, LLC’S MOTION FOR PRO HAC VICE ADMISSION
`OF ALFRED R. FABRICANT PURSUANT TO 37 C.F.R. § 42.10
`
`Case No. IPR2016-00418
`__________________________________________________________________
`
`
`
`
`
`
`
`
`
`
`
`I, Alfred R. Fabricant, declare as follows:
`
`
`
`
`
`
`
`IPR2016-00418
`PATENT NO. 8,155,342
`
`1.
`
`I have been practicing in the field of patent litigation for over 20 years. I
`
`have been lead counsel in over 30 patent cases over my career.
`
`2.
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`I am a member in good standing of the Bar of the State of New York and the
`
`Bar of the State of Arizona. I am admitted to practice in the United States District
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`Courts for the Southern District of New York, the Eastern District of New York,
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`the District of Arizona, and the Eastern District of Texas; the United States Courts
`
`of Appeal for the Federal Circuit, the Second Circuit, and the Fourth Circuit; and
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`the United States Supreme Court.
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`3.
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`I have never been suspended, disbarred, sanctioned, or cited for any
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`contempt by any court or administrative body.
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`4.
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`I have never had a court or administrative body deny my application for
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`admission to practice.
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`5.
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`I have read and will comply with the Office Patent Trial Practice Guide and
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`the Board’s Rules of Practice for Trials, as set forth in Part 42 of the Code of
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`Federal Regulations.
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`6.
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`I agree to be subject to the United States Patent and Trademark Office Code
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`of Professional Responsibility 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) and to be subject to the
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`USPTO Rules of Professional Conduct as set forth in Changes to Representation of
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`
`
`1
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`
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`IPR2016-00418
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`
`
`
`PATENT NO. 8,155,342
`
`
`
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`Others Before the United States Patent and Trademark Office; Final Rule, 78 Fed.
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`Reg. 20180 (Apr. 3, 2013) (effective May 3, 2013).
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`7.
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`In the past three (3) years, I have not been admitted pro hac vice in any
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`proceedings before the United States Patent and Trademark Office. I submitted a
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`declaration in connection with a motion for pro hac vice admission in IPR2016-
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`00118. That motion is still pending. I am also submitting declarations in
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`connection with motions for pro hac vice admission in the following inter partes
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`review proceedings: IPR2016-00419, -00421, and -00422. I plan to submit those
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`declarations and motions simultaneously with the instant declaration.
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`8.
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`I am familiar with the subject matter at issue in this proceeding. I am lead
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`counsel for the patent owner, Blitzsafe Texas, LLC, in five related patent
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`infringement matters involving the patent at issue in this proceeding, U.S. Patent
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`No. 8,155,342, and a related patent. Those matters are Blitzsafe Texas, LLC v.
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`Hyundai Motor Company, et al., No. 15-cv-01275-JRG (E.D. Tex.); Blitzsafe
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`Texas, LLC v. Honda Motor Co., Ltd., et al., No. 15-cv-01274-JRG (E.D. Tex.);
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`Blitzsafe Texas, LLC v. Volkswagen Group of America, Inc. et al., No. 15-cv-
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`01278-JRG (E.D. Tex.); Blitzsafe Texas, LLC v. Nissan Motor Co., Ltd., et al., 15-
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`cv-01276-JRG (E.D. Tex.); and Blitzsafe Texas, LLC v. Toyota Motor Corporation
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`et al., No. 15-cv-01277-JRG (E.D. Tex.) (“the Texas Litigations”).
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`9.
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`I hereby declare statements made herein of my own knowledge are true and
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`
`
`2
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`
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`IPR2016-00418
`
`PATENT NO. 8,155,342
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`that all statements made on information and belief are believed to be true; and
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`further that these statements are made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code and that such willful false
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`statements may jeopardize the validity of U.S. Patent No. 8,155,342.
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`Dated January 21, 2016
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`Respectfully submitted,
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`By:
`
`_,
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`Alfred R. Fabricant
`
`afabricant@,brownrudnick.c0m
`Brown Rudnick LLP
`
`7 Times Square
`New York, NY 10036
`Tel: 212-209-4800
`
`Fax. 212-209-4801
`
`
`
`IPR2016-00418
`
`
`
`
`PATENT NO. 8,155,342
`
`
`
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6(e)(4) & 42.105(b)
`
`
`
`A copy of the DECLARATION OF ALFRED R. FABRICANT IN
`
`SUPPORT OF BLITZSAFE TEXAS, LLC’S MOTION FOR PRO HAC VICE
`
`ADMISSION OF ALFRED R. FABRICANT PURSUANT TO 37 C.F.R. § 42.10
`
`has been served on Petitioner at the correspondence of the Petitioner as follows:
`
`SUGHRUE MION PLLC
`c/o William Mandir
`2100 Pennsylvania Ave NW
`Suite 800
`Washington, DC 20037
`toyota@sughrue.com
`
`
`January 21, 2016
`
`
`
`
`
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`
`
`
`
`By:
`
`
` /Peter Lambrianakos/
`
`
`Peter Lambrianakos (Reg. No. 58,279)
`Lead Counsel for Petitioner
`Brown Rudnick LLP
`7 Times Square
`New York, NY 10036
`Tel: 212-209-4800
`Fax: 212-209-4801
`
`
`
`
`
`
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