`________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
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`BRIGHT HOUSE NETWORKS, LLC
`WIDEOPENWEST FINANCE, LLC
`KNOLOGY OF FLORIDA, INC.
`BIRCH COMMUNICATIONS, INC.
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`Petitioner
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`v.
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`FOCAL IP, LLC,
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`Patent Owner
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`________________
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`Case IPR2016-01262
`Patent Number: 7,764,777
`________________
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`DECLARATION OF THOMAS C. CECIL IN SUPPORT OF UNOPPOSED
`MOTION FOR PRO HAC VICE ADMISSION
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` 1
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`BHN, et al. v. FOCAL IP, LLC
`FOCAL IP EX2071
`CECIL DECLARATION
`IPR2016-01262
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`I, Thomas C. Cecil, 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 over seven years.
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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: taking depositions of expert witnesses
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`regarding invalidity and infringement; assisting experts in drafting expert reports
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`regarding invalidity and infringement; drafting claim construction briefs; drafting
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`briefs associated with motions for summary judgment regarding invalidity and
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`infringement issues; drafting invalidity and infringement contentions; and
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`presenting argument in patent-related hearings.
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`4. I am a member in good standing of the State Bar of Texas, and the State
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`Bar of Missouri. I am also admitted to practice before the U.S. Court of Appeals
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`for the Federal Circuit, the United States District Court for the Eastern District of
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`Texas, and the United States District Court for the Northern District of Texas.
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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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` 2
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`BHN, et al. v. FOCAL IP, LLC
`FOCAL IP EX2071
`CECIL DECLARATION
`IPR2016-01262
`
`
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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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`IPR2016-01522 and IPR2017-01017.
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`11. I have an established familiarity with the subject matter at issue in this
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`proceeding. I have substantively reviewed all materials filed in this Inter Partes
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`Review, including the Petition for Inter Partes Review and all accompanying
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`exhibits, and the Preliminary Response to the Petition for Inter Partes Review and
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`all accompanying exhibits. I am thus very familiar with the subject matter in this
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`proceeding.
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`12. I declare under penalty of perjury that the foregoing is true and correct.
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` 3
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`BHN, et al. v. FOCAL IP, LLC
`FOCAL IP EX2071
`CECIL DECLARATION
`IPR2016-01262
`
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`August 10, 2017
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`Respectfully submitted,
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`/s/ Thomas C. Cecil
`Thomas C. Cecil
`Nelson Bumgardner, P.C.
`3131 W. 7th Street
`Suite 300
`Fort Worth, Texas 76107
`P: 817.806.3812
`F: 817.377.3485
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` 4
`
`BHN, et al. v. FOCAL IP, LLC
`FOCAL IP EX2071
`CECIL DECLARATION
`IPR2016-01262
`
`