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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
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`v.
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`IMAGE PROCESSING TECHNOLOGIES, LLC,
`Patent Owner
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`Case IPR2017-00355
`Patent 7,650,015 B2
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`
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`DECLARATION OF ROSE CORDERO PREY IN SUPPORT OF
`PATENT OWNER’S MOTION FOR PRO HAC VICE
`ADMISSION UNDER 37 C.F.R. §42.10(c)
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`Exhibit 2006
`IPR2017-00355
`Petitioner - Samsung Electronics Co., Ltd., et al.
`Patent Owner - Image Processing Technologies LLC
`1
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`I, Rose Cordero Prey, declare as follows:
`1.
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`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. This declaration is given in support of Image Processing Technologies,
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`LLC’s Motion for Pro Hac Vice Admission of Rose Cordero Prey under 37
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`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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`If admitted pro hac vice in this matter, I will serve as counsel with Chris
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`Coulson, also of the law firm Andrews Kurth Kenyon. Mr. Coulson is lead
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`counsel on this case and is registered to practice in this Court.
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`5.
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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
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`cases in many district courts and before the U.S. International Trade
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`Commission. I have been counsel at trial, hearings, and with respect to
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`patent-related summary judgment proceedings and other patent-related
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`hearings and pleadings concerning, inter alia, patent validity, claim
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`construction, and infringement issues. I have also been counsel in three
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`Inter Partes Review proceedings.
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`6.
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`I received a Bachelor’s of Science degree in Mathematics with a minor in
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`Physics in 2001.
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`2
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`7.
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`I am trial counsel for Patent Owner and have been actively involved in all
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`aspects of the Eastern District of Texas court proceeding against Petitioner
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`involving the same patents and technology (Image Processing
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`Technologies, LLC v. Samsung Electronics Co., Ltd., et al., 2:16-cv-00505-
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`JRG). Consequently I have gained in-depth familiarity with the subject
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`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 taken to
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`date in the present matter (Case IPR2017-00355), and have carefully
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`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 as
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`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 District Court for the Eastern District of Texas; and
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`United States Court of Appeals for the Federal Circuit.
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`10. I have never been suspended or disbarred from practice before any court or
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`administrative body.
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`11. I have never made an application for admission to practice before any court
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`or administrative body that has been denied.
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`3
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`12. No sanctions or contempt citations have been imposed against me by any
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`court or administrative body.
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`13. 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 Title 37 of
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`the Code of Federal Regulations.
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`14. 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
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`jurisdiction under 37 C.F.R. § 11.19(a).
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`15. I have applied to appear pro hac vice in three proceedings before the
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`United States Patent and Trademark Office in the last three (3) years,
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`Micron Technology, Inc. and Micron Memory Japan, Inc. v. Massachusetts
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`Institute of Technology, IPR2015-01087; Apple Inc., v. Limestone memory
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`Systems LLC, IPR2016-01561; and Apple Inc. v. Limestone Memory
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`Systems LLC, IPR2016-01567.
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`16. Motions for Pro Hac Vice Admission of Ms. Prey are being concurrently
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`filed in the following related Inter Partes Review proceedings:
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`i. IPR2017-00347
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`ii. IPR2017-00353
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`iii. IPR2017-00336
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`iv. IPR2017-00357
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`4
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`17. I declare that all statements made herein of my own knowledge are true and
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`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
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`willful false statements and the like so made are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code.
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`Executed on April 14, 2017
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`5
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