`
`
`
`__________________
`
`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)
`
`
`
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`__________________
`
`PRIME FOCUS CREATIVE SERVICES CANADA INC.
`Petitioner
`v.
`LEGEND3D, INC.
`Patent Owner
`
`
`
`__________________
`
`CASE IPR2016-01243
`Patent No. 7,907,793
`
`__________________
`
`
`
`
`Case No.: IPR2016-01243
`
`
`
`
`
`
`
`
`
`Docket No.: LF-L0015
`
`
`
`I, Danna J. Cotman, declare:
`
`I am competent to present this declaration given in support of the Motion for
`
`Pro Hac Vice Admission of Danna J. Cotman by Patent Owner Legend3D, Inc.
`
`(“Legend3D”), I have personal knowledge of the facts contained herein, and as to
`
`those facts I hereby attest to the following:
`
`1.
`
`I am a member in good standing of the Bar of the State of California
`
`(State Bar Number 188245) admitted in June 1997.
`
`2.
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`I have not been suspended or disbarred from practice before any court
`
`or administrative body.
`
`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
`
`any court or administrative body.
`
`5.
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`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 of 37 C.F.R.
`
`6.
`
`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. §
`
`11.19(a).
`
`7.
`
`I previously applied and was granted pro hac vice admission before
`
`the Office in Legend3D, Inc. v. Prime Focus VFX Services II Inc. Inter Partes
`
`
`
`1
`
`
`
`Case No.: IPR2016-01243
`
`
`
`
`
`
`
`
`
`Docket No.: LF-L0015
`
`
`
`Review petition (IPR2015-01350) and in Legend3D, Inc. v. Prime Focus VFX
`
`Services II Inc. Inter Partes Review petition (IPR2016-00806) .
`
`8.
`
`I am an experienced litigation attorney, with ten (10) years of
`
`experience litigating patent cases in federal courts. My experience includes
`
`representing clients in other intellectual property related litigation as well. I have
`
`appeared as counsel for Legend3D in a number of litigation matters (including
`
`patent litigation) over the span of my career. Further, I am currently lead counsel
`
`for the defense in the related patent infringement lawsuit entitled Prime Focus
`
`Creative Services Canada, Inc. v. Legend3D, Inc., United States District Court,
`
`Central District of California, Case No. 2:15-cv-02340-MWF-PLA, and I therefore
`
`know the issues involved in that case which overlap with numerous issues involved
`
`in this proceeding.
`
`9.
`
`Lead counsel Joseph J. Mayo with our office is a registered
`
`practitioner (Reg. No. 53288). I have worked with lead counsel in all aspects of
`
`preparing Legend3D’s two previous Inter Partes Reviews petitions and
`
`Declarations in support thereof. From my experience, I am familiar with the
`
`established practices of the Board.
`
`10. Lastly, counsel for the parties hereto have an agreement for non-
`
`opposition to any pro hac vice motion of counsel for the other party to this
`
`proceeding. (LEGEND3D Ex. 1017)
`
`
`
`2
`
`
`
`Case No.: lPR20 16-01243
`
`Docket No.: LF-L001 5
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true;
`
`and fiirther that these statements are made with knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`Executed on July 12, 2016
`
`
`
`Danrl./a"'J. Cotman
`
`
`
`Case No.: IPR2016-01243
`
`
`
`
`
`
`
`
`
`Docket No.: LF-L0015
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 Code of Federal Regulations § 42.6, the undersigned certifies
`
`
`
`
`
`that on July 12, 2016, a copy of the foregoing document was served via Express
`
`Mail on counsel of record identified below, and a courtesy copy was sent
`
`electronically, and that this document was filed with the Patent Trial and Appeal
`
`Board via the PTAB End-to-End System.
`
`IRELL & MANELLA LLP
`Joshua Glucoft, Esq.
`Jonathan S. Kagan
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067-4276
`PrimeFocusIPR@irell.com
`
`
`/Marie L. Acosta/
`
`4
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