`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`
`
`
`
`KAWASAKI RAIL CAR, INC.
`Petitioner,
`
`v.
`
`SCOTT BLAIR,
`Patent Owner.
`
`
`
`
`Case No. IPR2017-01036
`
`Patent No. 6,700,602
`
`Issue Date: March 2, 2004
`
`Title: Subway TV Media System
`
`
`
`DECLARATION OF MARK A. CHAPMAN
`
`
`
`
`
`
`1
`
`KAWASAKI-1033
`
`
`
`
`
`I, Mark A. Chapman, declare as follows:
`
`1.
`
`This declaration is given in support of Petitioner Kawasaki Rail Car, Inc.’s
`
`Motion for Pro Hac Vice Admission of Mark A. Chapman under 37 C.F.R.
`
`§ 42.10(c).
`
`2.
`
`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.
`
`3.
`
`If admitted pro hac vice in this matter, I will serve as back up counsel with
`
`Sheila Mortazavi, also of the law firm Andrews Kurth Kenyon LLP. Ms.
`
`Mortazavi is lead counsel and is a registered practitioner.
`
`4.
`
`I have over 15 years of 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.
`
`5.
`
`The proceedings before the Patent Office for which I have applied to appear
`
`pro hac vice in the last three years are as follows:
`
`a. Inter Partes Review Case No. IPR2015-01838
`
`b. Inter Partes Review Case No. IPR2016-00291
`
`c. Inter Partes Review Case No. IPR2016-00292
`
`d. Inter Partes Review Case No. IPR2016-00293
`
`2
`
`
`
`
`
`e. Inter Partes Review Case No. IPR2016-01382
`
`f. Inter Partes Review Case No. IPR2017-00117
`
`g. Inter Partes Review Case No. IPR2017-00336
`
`h. Inter Partes Review Case No. IPR2017-00347
`
`i. Inter Partes Review Case No. IPR2017-00353
`
`j. Inter Partes Review Case No. IPR2017-00355
`
`k. Inter Partes Review Case No. IPR2017-00357
`
`6.
`
`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.
`
`7.
`
`I am familiar with the subject matter of this proceeding. In particular:
`
`a. I have reviewed the subject U.S. Patent No. 6,700,602 (Ex. 1001).
`
`b. I have also reviewed the Petition (Paper No. 2), the prior art
`
`references at issue (Exs. 1005, 1009, 1011, 1021, 1025, 1026, 1028),
`
`and the declaration and supplemental declaration of Petitioner’s expert
`
`(Exs. 1015, 1029).
`
`c. I have also reviewed the Patent Owner’s Preliminary Response (Paper
`
`No. 6), the Board’s Institution Decision (Paper No. 10), the Patent
`
`Owner’s Response (Paper No. 15), and the declarations and
`
`3
`
`
`
`
`
`supplemental declaration of Patent Owner’s experts (Exs. 2002, 2006,
`
`2007).
`
`d. I have also reviewed the transcript of the deposition of Petitioner’s
`
`expert (Ex. 2008).
`
`e. I have also discussed the strategy, arguments and evidence in this
`
`proceeding with Ms. Mortazavi. Based on my patent litigation
`
`experience, I am very familiar with the legal theories at issue in this
`
`case.
`
`f. In addition, I have also applied for pro hac vice admission to appear in
`
`Petitioner’s co-pending proceeding against Patent Owner, Inter Partes
`
`Review Case No. IPR 2017-00117, in which a trial has been instituted
`
`against additional claims of the same patent at issue in this
`
`proceeding. I have discussed the strategy, arguments and evidence in
`
`that related proceeding with Ms. Mortazavi as well.
`
`8.
`
`Given my familiarity with the subject matter of this proceeding, I have
`
`experience and expertise important to representing Petitioner in this matter.
`
`9.
`
`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 of 37 C.F.R.
`
`4
`
`
`
`
`
`10.
`
`I have read and will comply with and be subject to the United States 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).
`
`
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true;
`
`and further that these statements were made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`Dated: January 5, 2018
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Mark A. Chapman
`
`5
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
