`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`UNIFIED PATENTS INC.,
`Petitioner
`
`v.
`
`PLECTRUM LLC
`Patent Owner
`
`
`Case: IPR2017-01430
`Patent 5,978,951
`
`
`AFFIDAVIT OF C. RYAN PINCKNEY
`IN SUPPORT OF MOTION FOR PRO HAC VICE ADMISSION
`
`
`
`1.
`
`I, C. Ryan Pinckney, am more than twenty-one years of age, am
`
`competent to present this affidavit, and have personal knowledge of the facts
`
`below.
`
`2.
`
`3.
`
`This affidavit supports Plectrum’s motion for pro hac vice admission.
`
`I hold the position of counsel at the law firm Antonelli, Harrington, &
`
`Thompson LLP.
`
`4.
`
`I have been a litigating attorney for more than eleven years. I have
`
`been litigating patent cases for more than eleven years.
`
`5.
`
`I am a member in good standing in the bar of Texas and the U.S.
`
`District Court for the Eastern District of Texas. I have never been suspended or
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`disbarred from practice before any court or administrative body.
`
`6.
`
`No court or administrative body has ever denied my application for
`
`admission to practice before it.
`
`7.
`
`No court or administrative body has ever imposed sanctions or
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`contempt citations on me.
`
`8.
`
`I have read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in Part 42 of Title 37 of
`
`the Code of Federal Regulations.
`
`9.
`
`I agree to be subject to the USPTO Code of Professional
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`Responsibility set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction
`
`
`
`under 37 C.F.R. § 11.19(a).
`
`10.
`
`I have applied to appear pro hac vice in four other proceedings before
`
`the Office in the last three (3) years. Specifically, I applied for and was granted
`
`admission pro hac vice in four IPR proceedings captioned St. Jude Medical, LLC v.
`
`Snyders Heart Valve LLC: IPR2018-00105, IPR2018-00106, IPR2018-00107, and
`
`IPR2018-00109.
`
`11.
`
`In a related matter involving the ‘951 Patent, I am representing Patent
`
`Owner Plectrum in a litigation previously pending in the Eastern District of Texas.
`
`See Plectrum LLC v. AT&T Inc. et al., No. 4:17-cv-00120. As a result, I have
`
`reviewed the ‘951 Patent and its relevant file history, and the prior art (including
`
`the prior art at issue in this Inter Partes Review proceeding). In addition, I have
`
`familiarity with the claim construction issues pertaining to the ‘951 Patent.
`
`12.
`
`I have performed a detailed review of the ‘951 Patent, the parties’
`
`submissions in the present Inter Partes Review proceeding, and the Board’s
`
`Decisions instituting Inter Partes Review of the ‘951 Patent. Additionally, I have
`
`served an essential role in this Inter Partes Review proceeding, including working
`
`with the present Lead and Backup Counsel to prepare the Preliminary Response
`
`and the Response. Based on the foregoing, I have a detailed understanding of the
`
`‘951 Patent and the substantive and technical issues involved in this proceeding.
`
`13.
`
`I declare that all statements made herein of my own knowledge are
`
`
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`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,
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`under Section 1001 of Title 18 of the United States Code.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`
`Dated: July 17, 2018
`
`
`Respectfully submitted,
`
`/s/ C. Ryan Pinckney
`C. Ryan Pinckney, Esq.
`
`
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