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UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SEMICONDUCTOR COMPONENTS INDUSTRIES, LLC
`d/b/a ON SEMICONDUCTOR,
`Petitioner
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`v.
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`POWER INTEGRATIONS, INC.,
`Patent Owner
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`1
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`PI 2017
`ON Semiconductor v. Power Integrations
`IPR2016-01600
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`Case IPR2016-01600
`Patent No. 7,834,605
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`DECLARATION OF HOWARD G. POLLACK IN SUPPORT OF PATENT
`OWNER’S MOTION FOR PRO HAC VICE ADMISSION
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`

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`Docket: 10256-0021IPC
`Case IPR2016-01600
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`DECLARATION OF HOWARD G. POLLACK IN
`SUPPORT OF PATENT OWNER’S MOTION FOR
` PRO HAC VICE ADMISSION
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`I, HOWARD G. POLLACK, hereby declare to the following:
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`1.
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`I am a member in good standing of the State Bar of California, and am
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`admitted to practice in the United States District Courts for the Northern, Central,
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`and Southern Districts of California, and the United States Court of Appeals for the
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`Federal Circuit. I am co-lead counsel for Patent Owner Power Integrations, Inc. in
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`several pending litigation matters, including in Power Integrations, Inc. v.
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`Fairchild Semiconductor International, Inc. et al, Case No. 08-00309 (D. Del.), a
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`co-pending district court case concerning, inter alia, U.S. Patent No. 7,834,605.
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`2.
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`I have not been suspended or disbarred from practice before any court or
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`administrative body.
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`3.
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`I have never had an application for admission to practice before any court or
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`administrative body denied on the basis of ethical or moral or ethical character or
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`ethical breach.
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`4.
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`No sanction or contempt citation has been imposed against me by any court
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`or administrative body.
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`5.
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`I have read and will comply with the Office Patent Trial Practice Guide and
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`the Board’s Rules of Practice for Trials set forth in part 42 of the Code of Federal
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`Regulations.
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`2 
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`

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`I will be subject to the USPTO Rules of Professional Conduct set forth in 37
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`Docket: 10256-0021IPC
`Case IPR2016-01600
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`6.
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`C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`7.
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`In the past three years, I have applied for and been granted admission pro
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`hac vice in IPR2014-00388 and IPR2016-00809. I am currently applying for pro
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`hac vice admission in: IPR2016-01589; IPR2016-01590; IPR2016-01592;
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`IPR2016-01594; IPR2016-01595; and IPR2016-01597.
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`8.
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`I am an experienced litigation attorney with more than 20 years of
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`experience representing clients in patent cases involving mechanical devices,
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`optical devices, electrical devices, computer hardware, computer software, the
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`Internet, and semiconductors. I regularly litigate patent cases in various forums
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`including the United States Court of Appeals for the Federal Circuit, federal
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`district courts, and the International Trade Commission. Through my experience
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`in patent litigation matters, I have represented clients in many phases of litigation
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`including discovery, Markman hearings, jury trials, bench trials, and appeals. I
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`have also been substantively involved in developing technical and legal arguments,
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`and working with technical experts and inventors.
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`9.
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`I have particular experience relevant to the patent-at-issue, having been co-
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`lead counsel on one case involving this patent, a currently pending suit adverse to
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`Fairchild in the District of Delaware (identified in paragraph 1 above). I have also
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`served as counsel for the Patent Owner since 1998 in intellectual property matters
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`3 
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`involving, among others, power supply integrated circuit controller technology. In
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`Docket: 10256-0021IPC
`Case IPR2016-01600
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`the litigation matters, I have overseen all phases of the litigations from discovery
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`through claim construction, including expert discovery and trial.
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`10. My biography is attached hereto as Appendix A.
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`11.
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`I began my legal career as a clerk for the Honorable Haldane Robert Mayer
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`on the United States Court of Appeals for the Federal Circuit from 1992 to 1994.
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`Additionally, I served as the Managing Principal of Fish & Richardson’s Silicon
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`Valley office from 2007 to 2015.
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`12.
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`I have read and analyzed the patent-at-issue in this proceeding, the petition,
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`the preliminary response and cited portions of the accompanying exhibits.
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`4 
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`

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`Docket: 10256—00211PC
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`Case IPR2016—Ol 600
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`13.
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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 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 and that such willful false
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`statements may jeopardize the validity of the application or any patents issued
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`thereon.
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`Date: 5'45”]?
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`Respectfully submitted,
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`
`52—01'
`
`
`HOWARD G OLLACK
`
`Fish & Richardson RC.
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`
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`500 Arguello Street, Suite 500
`Redwood City, CA 94063
`Tel: (650) 839-5070
`Email: pollack@fr.com
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`

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` Menu
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` Fish Team
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`
`
`Howard G. Pollack
`Principal
`
` 
`
` Redwood City, CA  650-839-5007
` Download vCard
`
` pollack@fr.com
`
`
`Background
`
`Howard G. Pollack is a Principal of Fish & Richardson’s Silicon Valley offce. Mr. Pollack joined the frm
` in 1994 after serving as judicial clerk to the Honorable H. Robert Mayer, United States Court of
` Appeals for the Federal Circuit (1992-1994). His litigation experience is primarily in the electronics,
` semiconductor and computer software felds and he has represented major clients in both patent and
` trademark infringement cases relating to those areas of technology. He has represented clients in
` patent litigation matters in several U.S. District Courts, the United States Court of Appeals for the
` Federal Circuit, and the U.S. International Trade Commission.
`
`Education
` J.D., Georgetown University Law Center 1992
`
`cum laude
`
` B.S., Stanford University 1988
`
`General Engineering
`
` A.B., Stanford University 1988
`
`Drama
`with honors
`
`Menu
`
`MENU
`
`APPENDIX A
`
`6
`
`

`

`Admissions
`• California 1992
`• U.S. Court of Appeals for the Federal Circuit
`
`Clerkships
`United States Court of Appeals for the Federal Circuit, The Honorable Haldane Robert Mayer, 1992 -
` 1994
`
`Other Distinctions
`Selected publications
`"The Admissibility and Utility of Expert Legal Testimony in Patent Litigation," 32 IDEA 361 (1992).
`
`"Is the Method of Doing Business Rejection Bankrupt?" 3 Fed. Cir. Bar J. 73 (1993) (with E. Robert
` Yoches).
`
`"The Gordian Algorithm: An Attempt to Untangle the International Dilemma Over the Protection of
` Computer Software," 22 Law & Pol’y Int’l Bus. 815 (1991).
`
`"Minimizing the Risk of a Finding of Willful Infringement Through Opinions of Counsel" (1991).
`
`Services
`• Litigation
`• Appellate
`• Patent Litigation
`
`Industries
`• Electrical and Computer Technology
`• Hardware
`• Semiconductors
`• Software
`
`7
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`

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`Experience
`Current
`
`Power Integrations, Inc. v. Fairchild and System General – Representing Power Integrations as co-
`lead counsel in the Northern District of California in asserting infringement claims related to Power
` Integrations’ prior successful suit in the U.S. ITC against System General. On March 4, 2014 a Jury
` returned a verdict in favor of Power Integrations, fnding Fairchild to have infringed and induced
` infringement of both Power Integrations’ patents-in-suit. The jury also found that Power Integrations
` had not infringed Fairchild’s counter-claim patent. The District Court also granted Summary Judgment
` that Power Integrations did not infringe a second patent Fairchild had asserted in its counterclaim. In
` December 2015, a jury awarded Power Integrations nearly $240 million in damages. Post-trial
` motions are currently pending.
`
`Power Integrations, Inc. v. Fairchild Semiconductor – Representing Power Integrations, Inc. as co-
`lead counsel in bringing a patent infringement suit in the District of Delaware. At issue are four Power
` Integrations patents relating to circuits and high voltage transistor structures asserted against various
` Fairchild chips used in power conversion applications. After trial, the jury found all four patents
` willfully infringed. After a second trial, a second jury found all asserted claims not invalid. After a
` bench trial, the Court found Fairchild to have willfully infringed. On appeal, the Federal Circuit
` affrmed-in-part, reversed-in-part, and remanded the case in the District of Delaware for further
` proceedings on damages and willful infringement.
`
`Power Integrations, Inc. v. Fairchild Semiconductor and System General [PI v. Fairchild II] –
` Representing Power Integrations, Inc. as co-lead counsel in asserting additional infringement claims
` against Fairchild and its subsidiary System General for their continued infringement of Power
` Integrations’ proprietary power supply controller technology. After a liability trial, Fairchild was found
` to infringe three Power Integrations patents and the infringed claims were held not invalid. The Court
` granted an injunction against further infringement and this case is on appeal to the Federal Circuit.
`
`Power Integrations, Inc. adv. Fairchild and System General – Representing Power Integrations,
` Inc. as co-lead counsel in the District of Delaware in defending against claims of infringement initiated
` by Fairchild. Power Integrations has asserted counterclaims in this matter. In June of 2015, a jury
` returned a mixed verdict, partially in favor of both parties. Post-trial motions are currently pending.
`
`SRI International, Inc. v. Cisco – Representing SRI International, Inc. in the District of Delaware in
` enforcing its Network Intrusion Detection patents against Cisco. In May 2016, the jury found Cisco
` willfully infringed SRI’s patents, awarding $23.7 million in damages. Post-trial motions are currently
` pending.
`
`8
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`

`

`SunPower Corp. v. PanelClaw, Inc. – Representing SunPower Corp. in the District of Delaware
` asserting patents related to solar panel commercial mounting systems. The case is in its early stages.
`
`Past
`
`Honeywell, Inc. v. Sandel Avionics – Successfully represented Sandel as co-lead counsel in
` securing a jury verdict of non-infringement on all remaining claims asserted by Honeywell stemming
` from its original complaint fled against Sandel in 2002 asserting infringement of fve Honeywell
` patents. Other of the asserted patent claims were previously held invalid on summary judgment and
` the invalidity fndings were affrmed on appeal. The patents-in-suit relate to FAA mandated Terrain
` Awareness and Warning Systems ("TAWS").
`
`Honeywell, Inc. v. Sandel Avionics, Inc. et al. (Sandel II) – Successfully represented Sandel as lead
` trial counsel in securing a jury verdict of noninfringement in a second case brought by Honeywell
` against Sandel in the District of Delaware. The patent at issue in this case was also related to Terrain
` Awareness and Warning Systems for aircraft but was directed to older technology concerning the pre-
`cursor "Ground Proximity Warning System." Honeywell asserted this patent against Sandel mid-way
` through the frst lawsuit involving fve other TAWS patents and the claim resulted in a follow-on suit.
`
`Power Integrations, Inc. v. BCD Semiconductor – Represented Power Integrations as co-lead
` counsel in the District of Delaware asserting infringement by BCD of three Power Integrations patents.
` Technology at issue relates to power supply controller integrated circuits. This matter settled with the
` Defendant agreeing to a consent judgment against further infringement.
`
`Power Integrations, Inc. v. Motorola, Inc. – Successfully represented Power Integrations, Inc. in a
` fve patent case relating to various aspects of chips used in high-voltage AC-to-DC power conversion.
` Primarily responsible for preparation of damages case which, at trial, resulted in the jury awarding
` Power Integrations $32.3 million in damages which, at the time, was the largest patent damages
` awards in Delaware history.
`
`In re Certain Power Supply Controllers and Products Containing Same – Successfully
` represented Power Integrations, Inc. as co-lead counsel in an investigation at the U.S. International
` Trade Commission concerning infringement of Power Integrations, Inc. patents by products of
` Respondent, System General Corporation of Taiwan. The ITC found infringement and entered an
` order excluding the accused products and certain downstream products incorporating them from the
` U.S. Successfully represented Power Integrations on appeal and secured a summary affrmance of
` the ITC decision.
`
`Cadence et al adv. Bhandari and Vanguard – Successfully represented Cadence as co-lead counsel
` in defending against claims for patent infringement in D. Texas and N.D. Cal. Technology at issue
`
`9
`
`

`

` relates to electronic design automation and verifcation tools. Secured summary judgment of non-
`infringement on declaratory judgment and dismissal of counterclaims.
`
`SRI International, Inc. v. Symantec Corporation and Internet Security Systems, Inc. –
` Successfully represented SRI Intentional, Inc. as a co-lead counsel in the District of Delaware in
` securing a jury verdict of infringement and patent validity against both defendants Symantec and
` Internet Security Systems, Inc. Technology at issue relates to computer network intrusion detection.
` This matter settled while on remand for a damages trial.
`
`SRI International, Inc. v. Fortinet, Inc. – Represented SRI International, Inc. SRI International, Inc. in
` a declaratory judgment matter brought by Fortinet, Inc. in the Northern District of California over
` infringement of SRI’s patents. The dispute relates to SRI patents previously litigated successfully and
` the technology relates to computer network intrusion detection. This matter settled.
`
`SRI International, Inc. adv. Check Point Software Technologies, Inc. – Representing SRI
` International, Inc. in a declaratory judgment matter brought by Check Point in the Northern District of
` California over infringement of SRI’s patents. The dispute relates to SRI patents previously litigated
` successfully and the technology relates to computer network intrusion detection. This matter settled.
`
`SRI International, Inc. adv. Dell and SecureWorks – Representing SRI International, Inc. in the
` District of Delaware in enforcing its network intrusion detection patents against Dell and its
` SecureWorks subsidiary related to their Managed Security Series (MSS). The case settled.
`
`ADE Corp. adv. KLA-Tencor, Corp. – Successfully represented ADE Corp. against KLA-Tencor’s
` claims of patent infringement in District of Delaware. Technology at issue concerned semiconductor
` wafer inspection instruments and related data analysis software. Won a jury verdict that all asserted
` claims of KLA’s remaining patent were invalid on multiple grounds. Succeeded in having claims to two
` other patents dismissed on summary judgment prior to trial and KLA-Tencor withdrew its claims on a
` fourth patent just prior to trial.
`
`Google v. Northestern University and Jarg, Inc. – Defended Google against claims for patent
` infringement brought in the Eastern District of Texas. Technology at issue techniques for searching
` large, distributed databases. This matter settled.
`
`Nest Labs, Inc. v. Honeywell International, Inc. – Representing Nest Labs, Inc. in defense of claims
` of infringement of seven Honeywell patents related to thermostats. The case settled after IPR
` proceedings were requested by Nest Labs.
`
`SunPower Corp. v. SunLink – Represented SunPower Corp. as co-lead counsel in the Northern
` District of California in asserting infringement of two SunPower patents by SunLink. Technology at
`
`10
`
`

`

` issue relates to lightweight structures for mounting arrays of solar panels on fat commercial rooftops
` with minimal or no roofng penetrations. This matter settled.
`
`Thales Airborne Systems, et al. v. Universal Avionics Systems Corp. – Represented Universal as
` lead counsel in defense of patent infringement claims brought by Thales in the District of Delaware.
` The two patents at issue in the case relate to Terrain Awareness and Warning Systems for aircraft.
` The matter settled.
`
`PLS-Pacifc Laser Systems v. TLZ, Inc. dba Toolz – Successfully represented Pacifc Laser as lead
` counsel in asserting its patent for a multi-beam laser alignment tool. Case settled prior to trial with
` defendant taking a license and agreeing to redesign the accused product.
`
`PLS-Pacifc Laser Systems v. Robotoolz et al – Represented PLS as lead counsel in breach of
` contract and patent infringement suit in the Northern District of California. Technology at issue relates
` to laser alignment tools. This matter settled.
`
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