`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`KAWASAKI RAIL CAR, INC.,
`
`Petitioner,
`
`v.
`
`SCOTT BLAIR,
`
`Patent Owner
`__________
`
`Case IPR2017-01036
`
`Patent 6,700,602
`
`DECLARATION OF DARIUSH KEYHANI IN SUPPORT OF PATENT OWNER’S
`MOTION FOR PRO HAC VICE ADMISSION
`
`
`
`Pursuant to 37 C.F.R. § 42.10(c), I, Dariush Keyhani, do hereby apply for pro hac vice
`
`admission to appear before the USPTO Patent Trial and Appeal Board on behalf of Patent Owner
`
`Scott Blair in the above-titled action.
`
`In support of this application, I certify the following under oath:
`
`1.
`
`I am a member of the law firm of Meredith & Keyhani, PLLC. My name, office
`
`address, and telephone number are as follows:
`
`Dariush Keyhani
`Meredith & Keyhani, PLLC
`125 Park Avenue, 25th Floor
`New York, New York 10017
`Tel. (212) 760-0098
`
`2.
`
`I have been admitted to the following courts and bars:
`
`Supreme Court of New Jersey (12/28/2002) (NJ Bar No. 0440622002)
`District of Columbia (4/11/2016)(D.C. Bar No. 1031500)
`United States District Court for New Jersey (2/3/2003)
`United States District Court for the Southern District of New York (1/20/2004)
`United States District Court for the Eastern District of New York (1/20/2004)
`United States District Court for the Western District of New York (10/22/2004)
`Second Circuit Court of Appeals (3/28/2012)
`Federal Circuit Court of Appeals (8/7/2013)
`
`3.
`
`I am an experienced patent litigation and trial attorney.
`
`I have practiced patent
`
`litigation for almost 15 years. During this period, I have served as lead litigation and trial counsel
`
`in over two dozen patent infringement. In almost all of these cases the validity of the patents was
`
`the subject of a claim and/or an affirmative defense.
`
`4.
`
`I am the lead litigation and trial counsel representing Scott Blair in parallel
`
`proceedings in federal district court for infringement U.S. Patent No. 6,700,602 (‘602 Patent,
`
`“Subway TV Media System”) and also defending the validity of the claims in connection with
`
`claims of invalidity brought by Kawasaki Rail Car, Inc. For over one and a half years, I have been
`
`preparing and prosecuting this case and have been in charge of overseeing all substantive issues
`
`2
`
`
`
`relating to infringement and validity of the patent. During this time, I have worked closely with
`
`the inventor to learn his invention disclosed in the ‘602 Patent and I have carefully studied the
`
`specification and claims of the ‘602 Patent. I have also carefully reviewed in detail all filings by
`
`the Petitioner and Patent Owner in connection with this IPR. I have also worked with two separate
`
`technical experts in understanding and learning the invention disclosed and claimed in the ‘602
`
`Patent. Additionally, I have worked closely and extensively with patent co-counsel Jennifer
`
`Meredith, who is also an engineer.
`
`I am regularly admitted pro hac vice in federal courts throughout the United States.
`
`I am currently in good standing with all states, courts, and bars in which I am
`
`5.
`
`6.
`
`admitted.
`
`7.
`
`I have never been suspended or disbarred from practice before any court or
`
`administrative body.
`
`8.
`
`None of my applications for admission to practice before any court or
`
`administrative body has ever been denied.
`
`9.
`
`No sanctions or contempt citations have ever been imposed against me by any court
`
`or administrative body.
`
`10.
`
`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.
`
`11.
`
`I understand that I will be subject to the Office’s 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) (Id. ¶
`
`9).
`
`3
`
`
`
`12.
`
`I have never applied for pro hac vice admission before the Board. I am applying
`
`for pro hac vice at the same time as the within application in a related matter (IPR Case IPR2017-
`
`00117).
`
`13.
`
`Lead counsel with whom I am associated in this matter is Jennifer Meredith, a
`
`registered practitioner (Reg. No. 47,790). She is an active member in good standing with the New
`
`York and Texas State Bars and is admitted before the United States Patent and Trademark Office,
`
`Southern District of New York, Eastern District of New York, Northern District of New York, and
`
`Western District of New York. Her office is located at 205 Main Street East Aurora, NY 14052.
`
`Her office phone number is (212) 760-0098.
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed in East
`
`Aurora, New York, this 3rd day of November 2017. Dated this this 3rd day of November 2017.
`
`Respectfully submitted,
`
`/s/ Dariush Keyhani
`Dariush Keyhani (DK-9673)
`Meredith & Keyhani, PLLC
`125 Park Avenue, 25th Floor
`New York, New York 10017
`Tel. (212) 760-0098
`Fax (212) 202-3819
`dkeyhani@meredithkeyhani.com
`
`4
`
`
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