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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`APPLE INC.,
`Petitioner,
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`v.
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`LIMESTONE MEMORY SYSTEMS LLC,
`Patent Owner.
`____________________
`
`Case IPR2016-01567
`Patent 5,894,441
`____________________
`
`AFFIDAVIT OF ROSE CORDERO PREY IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
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`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`Submitted Electronically via the PTAB E2E
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`Apple – Ex. 1024
`Apple Inc., Petitioner
`1
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`1.
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`I, Rose Cordero Prey, am more than twenty-one years of age, am
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`competent to present this affidavit, and have personal knowledge of the facts set
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`forth herein.
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`2.
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`This affidavit is given in support of Apple Inc.’s Motion for Pro Hac
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`Vice Admission of Rose Cordero Prey under 37 C.F.R. § 42.10(c).
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`3.
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`4.
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`I am a partner at the law firm of Andrews Kurth Kenyon LLP.
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`I am an experienced litigation attorney and have been litigating patent
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`cases for over 10 years. I have experience litigating patent infringement cases in
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`many district courts and before the U.S. International Trade Commission. I have
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`been counsel at trial, hearings, and with respect to patent-related summary
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`judgment proceedings and other patent-related hearings and pleadings concerning,
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`inter alia, patent validity, claim construction, and infringement issues.
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`5.
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`I received a Bachelor’s of Science degree in Mathematics with a
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`minor in Physics in 2001, and I have several years of experience litigating patents
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`specifically directed to semiconductor circuitry and device technology (the design,
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`fabrication and use thereof).
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`6.
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`I am trial counsel for Petitioner Apple Inc. in co-pending district court
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`litigation filed by the Patent Owner, Limestone Memory Systems LLC v. Apple Inc.,
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`Civil Action No. 8:15-cv-01274, filed August 10, 2015, in the U.S. District Court
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`for the Central District of California. That case involves the same patent at issue in
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`1
`
`Apple – Ex. 1024
`Apple Inc., Petitioner
`2
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`
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`this proceeding (U.S. Patent No. 5,894,441 or “the ’441 patent”).
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`7.
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`I have been actively involved in all aspects of the aforementioned
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`district court litigation, including Petitioner’s factual investigation and
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`development of its non-infringement, invalidity and other positions regarding the
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`claims of the ’441 patent, and have consequently gained in-depth familiarity with
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`the subject matter at issue in this proceeding.
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`8.
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`I have stayed up-to-date regarding the documents filed and actions
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`taken to date in the present matter, Case IPR2016-01567, was involved in the
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`preparation of Petitioner’s petition, and have carefully reviewed it.
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`9.
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`I am a member in good standing of the State Bar of New York, as well
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`as the following Federal Courts:
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`United States District Court for the Eastern District of New York;
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`United States District Court for the Southern District of New York;
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`United States Court of Appeals for the Federal Circuit.
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`10.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
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`11.
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`I have never made an application for admission to practice before any
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`court or administrative body that has been denied.
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`12. No sanctions or contempt citations have been imposed against me by
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`any court or administrative body.
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`2
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`Apple – Ex. 1024
`Apple Inc., Petitioner
`3
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`13.
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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 Title 37 of
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`the Code of Federal Regulations.
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`14.
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`I understand that I will be subject to the USPTO Rules of Professional
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`Conduct as set forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction
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`under 37 C.F.R. § 11.19(a).
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`15.
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`I have applied to appear pro hac vice in one proceeding before the
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`United States Patent and Trademark Office in the last three (3) years: IPR2015-
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`01087.
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`16.
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`I 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 further that these statements were made with the 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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`
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`Rose Cordero Prey
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`3
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`Executed on October 18, 2016
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`Apple – Ex. 1024
`Apple Inc., Petitioner
`4