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`__________________
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`DECLARATION OF DANNA J. COTMAN IN SUPPORT OF
`PATENT OWNER’S MOTION FOR ADMISSION PRO HAC VICE OF
`DANNA J. COTMAN UNDER 37 CFR § 42.10 (LEGEND3D EX.1016)
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`__________________
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`PRIME FOCUS CREATIVE SERVICES CANADA INC.
`Petitioner
`v.
`LEGEND3D, INC.
`Patent Owner
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`__________________
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`CASE IPR2016-01243
`Patent No. 7,907,793
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`__________________
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`Case No.: IPR2016-01243
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`Docket No.: LF-L0015
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`I, Danna J. Cotman, declare:
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`I am competent to present this declaration given in support of the Motion for
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`Pro Hac Vice Admission of Danna J. Cotman by Patent Owner Legend3D, Inc.
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`(“Legend3D”), I have personal knowledge of the facts contained herein, and as to
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`those facts I hereby attest to the following:
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`1.
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`I am a member in good standing of the Bar of the State of California
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`(State Bar Number 188245) admitted in June 1997.
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`2.
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`I have not been suspended or disbarred from practice before any court
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`or administrative body.
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`3.
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`I have never had an application for admission to practice before any
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`court or administrative body denied.
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`4. No sanctions or contempt citations have been imposed against me by
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`any court or administrative body.
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`5.
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`I have read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`6.
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`I will be subject to the USPTO Rules of Professional Conduct 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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`7.
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`I previously applied and was granted pro hac vice admission before
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`the Office in Legend3D, Inc. v. Prime Focus VFX Services II Inc. Inter Partes
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`1
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`Case No.: IPR2016-01243
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`Docket No.: LF-L0015
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`Review petition (IPR2015-01350) and in Legend3D, Inc. v. Prime Focus VFX
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`Services II Inc. Inter Partes Review petition (IPR2016-00806) .
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`8.
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`I am an experienced litigation attorney, with ten (10) years of
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`experience litigating patent cases in federal courts. My experience includes
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`representing clients in other intellectual property related litigation as well. I have
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`appeared as counsel for Legend3D in a number of litigation matters (including
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`patent litigation) over the span of my career. Further, I am currently lead counsel
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`for the defense in the related patent infringement lawsuit entitled Prime Focus
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`Creative Services Canada, Inc. v. Legend3D, Inc., United States District Court,
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`Central District of California, Case No. 2:15-cv-02340-MWF-PLA, and I therefore
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`know the issues involved in that case which overlap with numerous issues involved
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`in this proceeding.
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`9.
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`Lead counsel Joseph J. Mayo with our office is a registered
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`practitioner (Reg. No. 53288). I have worked with lead counsel in all aspects of
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`preparing Legend3D’s two previous Inter Partes Reviews petitions and
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`Declarations in support thereof. From my experience, I am familiar with the
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`established practices of the Board.
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`10. Lastly, counsel for the parties hereto have an agreement for non-
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`opposition to any pro hac vice motion of counsel for the other party to this
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`proceeding. (LEGEND3D Ex. 1017)
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`2
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`Case No.: lPR20 16-01243
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`Docket No.: LF-L001 5
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`I hereby declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true;
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`and fiirther that these statements are made with 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.
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`Executed on July 12, 2016
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`Danrl./a"'J. Cotman
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`Case No.: IPR2016-01243
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`Docket No.: LF-L0015
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 Code of Federal Regulations § 42.6, the undersigned certifies
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`that on July 12, 2016, a copy of the foregoing document was served via Express
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`Mail on counsel of record identified below, and a courtesy copy was sent
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`electronically, and that this document was filed with the Patent Trial and Appeal
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`Board via the PTAB End-to-End System.
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`IRELL & MANELLA LLP
`Joshua Glucoft, Esq.
`Jonathan S. Kagan
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067-4276
`PrimeFocusIPR@irell.com
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`/Marie L. Acosta/
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`4