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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`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 IPR2017-01218
`Patent 8,983,134 B2
`
`
`
`
`DECLARATION OF MICHAEL N. ZACHARY IN SUPPORT OF
`PATENT OWNER’S MOTION FOR PRO HAC VICE
`ADMISSION UNDER 37 C.F.R. §42.10(c)
`
`
`
`Exhibit 2004
`IPR2017-01218
`Petitioner - Samsung Electronics Co., Ltd., et al.
`Patent Owner - Image Processing Technologies LLC
`
`1
`
`
`
`
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`
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`I, MICHAEL N. ZACHARY, declare as follows:
`
`1. I am a partner at the law firm of Andrews Kurth Kenyon LLP, with offices
`
`located at One Broadway, New York, NY 10004, which has been retained
`
`by Patent Owner Image Processing Technologies, LLC in this inter partes
`
`review. My office is located at 1801 Page Mill Road, Suite 210, Palo Alto,
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`CA 94304, but for convenience, for purposes of this IPR petition I can
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`receive notices and be contacted through our New York office set forth
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`above.
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`2. I make this declaration in support of the Patent Owner’s application for my
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`admission pro hac vice.
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`3. I am a member in good standing of the Bar in California, Oregon, and
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`Washington State. I am also duly admitted and authorized to practice law
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`before the U.S. District Court for the Central District of California, U.S.
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`District Court for the Eastern District of California, U.S. District Court for
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`the Northern District of California, U.S. District Court for the Southern
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`District of California, U.S. District Court for the District of Colorado, U.S.
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`District Court for the District of Oregon, U.S. District Court for the Eastern
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`District of Texas, U.S. District Court for the Eastern District of Washington,
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`and U.S. District Court for the Western District of Washington.
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`
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`2
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`4. I have not had any application denied for admission to practice, nor have I
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`been sanctioned, cited for contempt, suspended or disbarred from practice,
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`before any court or administrative body.
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`5. 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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`6. I understand that, upon admission pro hac vice, I will be subject to the
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`USPTO Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et
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`seq. and to disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`7. 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 C.F.R.
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`8. I hereby agree to notify the Court immediately of any matter affecting my
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`standing at the bar of any other Court.
`
`I have appeared pro hac vice in the matters Microsoft Corp. v. Bradium
`
`Techs. LLC, IPR2015-01432; Microsoft Corp. v. Bradium Techs. LLC,
`
`IPR2015-01434; Microsoft Corp. v. Bradium Techs. LLC, IPR2015-01435;
`
`Microsoft Corp. v. Bradium Techs. LLC, 2016-00448; Microsoft Corp. v.
`
`Bradium Techs. LLC, IPR2016-00449; Microsoft Corp. v. Bradium Techs.
`
`LLC, 2016-01897; Prism Pharma Co., Ltd., v. Choongwae Pharma Corp.,
`
`IPR2014-00315; Apple Inc., v. Limestone Memory Systems LLC, IPR2016-
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`3
`
`
`
`
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`
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`01561; Apple Inc., v. Limestone Memory Systems LLC, IPR2016-01567. I
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`have pending pro hac vice motions in Samsung Electronics Co., Ltd., et al.
`
`v. Image Processing Technologies, LLC, IPR2017-00336; Samsung
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`Electronics Co., Ltd., et al. v. Image Processing Technologies, LLC,
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`IPR2017-00347; Samsung Electronics Co., Ltd., et al. v. Image Processing
`
`Technologies, LLC, IPR2017-00353; Samsung Electronics Co., Ltd., et al. v.
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`Image Processing Technologies, LLC, IPR2017-00355; Samsung
`
`Electronics Co., Ltd., et al. v. Image Processing Technologies, LLC,
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`IPR2017-00357. I have not applied to appear pro hac vice in any other
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`matters before the Office in the last three years.
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`9. I have an established familiarity with the subject matter at issue in this
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`proceeding, having represented Patent Owner against petitioner in an
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`Eastern District of Texas court proceeding against Petitioner involving the
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`same technology (Image Processing Technologies, LLC v. Samsung
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`Electronics Co., Ltd., et al., 2:16-cv-00505-JRG).
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`10. Motion for Pro Hac Vice Admission of Mr. Zachary is being concurrently
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`filed in IPR2017-01190.
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`11. I hereby respectfully request that the Court grant Patent Owner Image
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`Processing Technologies, LLC’s application to permit me to appear and
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`participate pro hac vice in this case.
`
`4
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`12. I understand that willful false statements and the like are punishable by fine
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`or imprisonment, or both, under 18 U.S.C. § 1001, and may jeopardize the
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`validity of the application or any patent issuing thereon. I declare under
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`penalty of perjury that the foregoing is true and correct.
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`Executed on January 8, 2018
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`
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`________________________
`MICHAEL N. ZACHARY
`
`
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`5
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`
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