`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`HYUNDAI MOTOR COMPANY LTD., HYUNDAI MOTOR AMERICA,
`
`HYUNDAI MOTOR MANUFACTURING ALABAIVIA, LLC, KIA MOTORS
`
`CORPORATION, KIA MOTORS AIVIERICA, INC.,
`
`KIA MOTORS MANUFACTURING GEORGIA, INC., NISSAN NORTH
`
`AMERICA, INC., NISSAN MOTOR CO., LTD., and AIVIERICAN HONDA
`
`MOTOR CO., INC.,
`
`Petitioner,
`
`v.
`
`BLITZSAFE TEXAS, LLC,
`
`Patent Owner.
`
`Case IPR2016-00418‘
`
`Patent 8,155,342 B2
`
`NISSAN MOTOR CO., LTD. AND NISSAN NORTH AMERICA, INC.’S
`AFFIDAVIT IN SUPPORT OF MOTION FOR
`
`PRO HAC VYCE ADMISSION OF MICHAEL T. MURPHY
`
`‘ Cases IPR2016-01533, IPR2016-01557, and IPR2016-01560 have been joined
`with this proceeding.
`
`
`
`1, Michael T. Murphy, being duly sworn and upon oath, hereby attest to the
`
`following pursuant to this Board’s decision in Unified Patents v. Parallel Iron, LLC,
`
`IPR2013-00639:
`
`i.
`
`I am a member in good standing of the Maryland and District of
`
`Columbia Bars, as well as the following Federal Courts: a) U.S. District Court for
`
`the District of Maryland; b) U.S. Court of Appeals for the Federal Circuit; and c)
`
`U.S. Court of Appeals for the Eleventh Circuit.
`
`ii.
`
`I have not been suspended or disbarred fi-om practice before any court
`
`or administrative body.
`
`iii.
`
`I have never had an application for admission to practice before any
`
`court or administrative body denied.
`
`iv.
`
`No sanction or contempt citation has been imposed against me by any
`
`court or administrative body.
`
`v.
`
`I have read and will comply with the Office Patent Trial Practice Guide
`
`and the Board’s Rules of Practice for Trials set forth in part 42 ofthe Code of Federal
`
`Regulations.
`
`vi.
`
`I will be subject to the USPTO Rules of Professional Conduct set forth
`
`in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. §
`
`ll.19(a).
`
`
`
`vii.
`
`I have not applied to appear pro hac vice before the Office in any other
`
`proceeding in the last three years.
`
`viii.
`
`I am an experienced litigation attorney, with experience in many
`
`litigations involving patent infringement in District Courts across the country,
`
`including experience with fact and expert document and deposition discovery, claim
`
`construction, Markman hearings, motion practice, trials and hearings.
`
`ix. My firm serves as counsel for Petitioner Nissan North America, Inc.
`
`with respect to patent prosecution matters.
`
`I am familiar with the subject matter at
`
`issue in this proceeding as a result of my firm’s representation of Nissan North
`
`America, Inc. with respect to patent prosecution matters. Additionally, I have
`
`counseled Petitioners on intellectual property matters related to their business.
`
`x.
`
`I declare that all statements made of my own knowledge are true and
`
`that all statements made on information and belief are believed to be true, and that
`
`these statements were made with the knowledge that willful false statements and the
`
`like are punishable by fine or imprisonment, or both under section 1001 of Title 18
`
`of the United States Code.
`
` Date: February 2, 2017
`
` Michael T.
`
`
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