`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
`
`v.
`
`IMAGE PROCESSING TECHNOLOGIES, LLC,
`Patent Owner
`
`Case IPR2017-00357
`Patent 8,989,445B2
`
`DECLARATION OF MARK A. CHAPMAN IN SUPPORT OF
`PATENT OWNER'S MOTION FOR PRO HAC VICE
`ADMISSION UNDER 37 C.F.R. §42.10(c
`
`Exhibit 2002
`IPR2017-00357
`Petitioner- Samsung Electronics Co., Ltd., et al.
`Patent Owner- Image Processing Technologies LLC
`
`1
`
`
`
`I, Mark A. Chapman, declare as follows:
`
`1. This declaration is given in support of Image Processing Technologies,
`
`LLC's Motion for Pro Hac Vice Admission of Mark A. Chapman under 37
`
`C.F.R. § 42.10(c).
`
`2.
`
`If admitted pro hac vice in this matter, I will serve as counsel with Chris
`
`Coulson, also of the law firm Andrews Kurth Kenyon LLP. Mr. Coulson is
`
`lead counsel and is a registered practitioner.
`
`3.
`
`I am a partner at the law firm Andrews Kurth Kenyon LLP, where my
`
`practice focuses on patent-related matters, and in particular, patent
`
`litigation in a variety of technical fields.
`
`4.
`
`I have over 15 years' experience in the field of patent law. My practice
`
`focuses on patent litigation in district courts around the country, appeals at
`
`the Federal Circuit, and Patent Office proceedings, such as reexaminations
`
`and inter partes review proceedings. For example, in the past several years,
`
`I have been involved in, inter alia, the following Patent Office inter partes
`
`reexaminations and inter partes review proceedings:
`
`a. Inter Partes Review Case IPR2015-01838 (admitted pro hac vice)
`
`b. Inter Partes Review Case IPR2016-00291 (admitted pro hac vice)
`
`c. Inter Partes Review Case IPR20 16-00292 (admitted pro hac vice)
`
`d. Inter Partes Review Case IPR20 16-00293 (admitted pro hac vice)
`
`2
`
`
`
`e. Inter Partes Review Case IPR20 16-013 82 (admitted pro hac vice)
`
`f. Reexamination Control No. 95/002,256, and related Appeal No. 2015-
`
`006,133 (P.T.A.B)
`
`g. Reexamination Control No. 95/001,504.
`
`h. Reexamination Control No. 95/001,630.
`
`5.
`
`I am a member in good standing of the New York Bar. I have not had any
`
`application denied for admission to practice, nor have I been sanctioned,
`
`cited for contempt, suspended or disbarred from practice, before any court
`
`or administrative body.
`
`6.
`
`I am familiar with the subject matter of this proceeding. I have reviewed
`
`the subject U.S. Patent No. 8,989,445, as well as the petition for inter partes
`
`review filed by Petitioner in this proceeding. I am counsel for Patent
`
`Owner in the related, co-pending litigation.
`
`7. Given my familiarity with the subject matter of this proceeding and my
`
`experience, I have experience and expertise important to representing
`
`Patent Owner Image Processing Technologies, LLC in this matter.
`
`8.
`
`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 42 of37
`
`C.P.R.
`
`9.
`
`I have read and will comply with and be subject to the United States
`
`3
`
`
`
`Patent and Trademark Office Rules of Professional Conduct set forth in
`
`37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R.
`
`§ 11.19(a).
`
`10. I declare that all statements made herein of my knowledge are true and
`
`that all statements made on information and belief are believed to be true,
`
`and further that these statements are made with knowledge that willful
`
`false statements and the like are punishable by fine or imprisonment, or
`
`both, under§ 1001 ofTitle 18 ofthe United States Code.
`
`Executed on April 14, 2017
`
`4
`
`
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