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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`CISCO SYSTEMS, INC.,
`Petitioner,
`
`v.
`
`TQ DELTA, LLC,
`Patent Owner.
`_____________
`
`Case IPR2016-01466
`Patent No. 8,611,404
`
`_____________
`
`DECLARATION OF RAJENDRA A. CHIPLUNKAR IN
`SUPPORT OF MOTION FOR PRO HAC VICE ADMISSION
`
`
`
`1
`
`TQ Delta Exhibit 2010
`
`Cisco Systems, Inc. v. TQ Delta, LLC
`
`
`
`IPR2016-01466
`
`
`
`
`
`I, Rajendra A. Chiplunkar, declare as follows:
`
`1.
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`I am an associate with the law firm of McAndrews, Held and Malloy,
`
`Ltd. in Chicago, Illinois.
`
`2.
`
`I have been practicing law for more than three years. My practice
`
`during this time has focused on intellectual property litigation, and particularly,
`
`patent litigation.
`
`3.
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`I am a member in good standing of the Bar of the State of Illinois and
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`am admitted to practice in the U.S. District Court for the Northern District of
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`Illinois.
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`4.
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`I have been admitted to practice pro hac vice in other Federal District
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`courts.
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`5.
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`I was the Vice-President of the Illinois State Bar Association
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`Intellectual Property Council and am a current member of the Illinois State Bar
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`Association Intellectual Property Council.
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`6.
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`I have experience in fact and expert document and deposition
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`discovery, and motion practice before U.S. District Courts in connection with
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`patent infringement litigation matters.
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`8.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
`
`
`
`2
`
`
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`9.
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`No court or administrative body has ever denied my application for
`
`admission to practice.
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`10. No court or administrative body has ever sanctioned me or cited me
`
`for contempt.
`
`11.
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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 37 C.F.R.
`
`Section 42.
`
`12.
`
`I agree to be subject to the United States Patent and Trademark
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`Office’s Rules of Professional Conduct 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).
`
`13.
`
`I have spent substantial time reviewing and analyzing the patent at
`
`issue in this proceeding, the patent file history, the Petition, the references cited,
`
`and the Declarations of Petitioner’s Expert and, therefore, am familiar with the
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`subject matter at issue in this proceeding.
`
`14. A motion for my admission to appear pro hac vice before the Patent
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`Trial and Appeal Board (the “Board”) was filed in IPR2014-01195 and the Board
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`granted said motion. See IPR2014-01195, Paper 35 (Sept. 8, 2015). Motions were
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`also filed in IPR2016-01469 (granted at Paper 21, April 25, 2017); IPR2016-01470
`
`(granted at Paper 22, April 25, 2017); IPR2016-01006 (granted at Paper 28, July 5,
`
`2017); IPR2016-01007 (granted at Paper 26, July 5, 2017); IPR2016-01008
`3
`
`
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`
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`(granted at Paper 28, July 5, 2017); IPR2016-01009 (granted at Paper 25, July 5,
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`2017), and IPR2016-01160 (granted at Paper 28, August 8, 2017).
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`I declare under penalty of perjury, under the laws of the United States of
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`America, that the forgoing is true and correct.
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`Dated: September 8, 2017
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`
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`Respectfully submitted,
`
`
`
`
`
`
`
`/s/ Rajendra A. Chiplunkar
`Rajendra A. Chiplunkar
`McAndrews, Held and Malloy, Ltd.
`500 West Madison Street, 34th Floor
`Chicago, IL 60661
`rchiplunkar@mcandrews-ip.com
`
`
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`
`4
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