`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________________________
`INTEL CORP., and
`CAVIUM, INC.,
`Petitioner,
`
`v.
`ALACRITECH, INC.,
`Patent Owner.
`________________________
`
`Case IPR2017-014061
`Patent 7,673,072
`
`DECLARATION OF KARINEH KHACHATOURIAN IN SUPPORT OF
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION
`
`
`
`1 Cavium, who filed a Petition in case IPR2017-01707, has been joined as a
`petitioner in this proceeding.
`
`
`
`IPR2017-01406
`Declaration of Karineh Khachatourian
`
`
`I, Karineh Khachatourian, declare the following:
`
`1.
`
`I am a partner in the law firm of Duane Morris LLP, working in the
`
`firm’s office in Palo Alto, California.
`
`2.
`
`I am a member in good standing of the California Bar.
`
`3. My California Bar member number is 202634.
`
`4.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`5.
`
`I have never had a court or administrative body deny my application
`
`for admission to practice.
`
`6.
`
`Other than my co-pending application for pro hac vice admission in
`
`IPR Trial Nos. IPR2017-01391, IPR2017-01392, IPR2017-01393, IPR2017-01405,
`
`IPR2017-01409, and IPR2017-01410 and IPR Trial Nos. IPR2015-01595,
`
`IPR2015-01078, IPR2015-01080, IPR2017-01071 and IPR2017-01070, I have not
`
`applied to appear pro hac vice in any other Patent Trial and Appeal Board
`
`(“PTAB”), or United States Patent and Trademark Office (“USPTO”), proceeding
`
`over the last three years.
`
`7.
`
`I have never had any court or administrative body impose sanctions or
`
`contempt citations against me.
`
`8.
`
`I have read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials, as set forth in Part 42 of C.F.R.
`
`
`
`IPR2017-01406
`Declaration of Karineh Khachatourian
`
`
`9.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`Code of Professional Responsibility set forth in 37 C.F.R. §§ 10.20 et seq., 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 am an experienced litigation attorney, with experience in many
`
`patent infringement litigations in District Courts across the country, including
`
`experience with fact and expert document and deposition discovery, claim
`
`construction, Markman hearings, motion practice, and trials and hearings.
`
`11.
`
`I have been lead counsel for Petitioner Cavium, Inc. in the ongoing
`
`litigation captioned , Alacritech, Inc. v. Dell Inc., Case No. 2:16-cv-00695 (filed
`
`Jun. 30, 2016) (“the co-pending litigation”) since its inception and have been
`
`actively involved in all aspects of the co-pending litigation, which relates to and
`
`involves the same patent at issue in this proceeding. I am familiar with the subject
`
`matter at issue in this proceeding as a result of my representation of Cavium, Inc.
`
`in the related litigation, including the prior art that Petitioner presents in this
`
`proceeding.
`
`12.
`
`I hereby declare that all statements 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 are made with the knowledge that willful false
`
`
`
`
`
`IPR2017-01406
`Declaration of Karineh Khachatourian
`
`and the like are punishable by fine, imprisonment, or both, under Section 1001 of
`
`Title 18 of the United States Code.
`
`Dated: February 14, 2018
`
`Respectfully Submitted,
`
`/ Karineh Khachatourian /
`Karineh Khachatourian
`DUANE MORRIS LLP
`2475 Hanover St.
`Palo Alto, CA 94304-1194
`Telephone: (650) 847-4150
`Fax: (650) 847-4151
`
`
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