`Patent No. 7,067,952
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`________________
`
`TOYOTA MOTOR CORPORATION AND DENSO CORPORATION,
`Petitioners
`
`v.
`
`INTELLECTUAL VENTURES II LLC,
`Patent Owner
`
`________________
`
`Case No. IPR2017-01497
`Patent No. 7,067,952
`
`________________
`
`DECLARATION OF PATRICK T. DRISCOLL IN SUPPORT OF
`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
`
`Intellectual Ventures Exhibit 2004
`Toyota Motor Corp et al. v. Intellectual Ventures
`IPR2017-01497
`
`
`
`Case IPR2017-01497
`Patent No. 7,067,952
`
`I, Patrick T. Driscoll, being duly sworn and upon oath, hereby attest to the
`
`following:
`
`1.
`
`I am an Associate at Mintz Levin Cohn Ferris Glovsky and Popeo PC with
`
`five years of experience litigating patents.
`
`2.
`
`I am a member in good standing of the Bar of the state of Massachusetts
`
`(Bar # 682489), as well as the United States District Court for the District of
`
`Massachusetts.
`
`3.
`
`I have not been suspended or disbarred from practice before any court or
`
`administrative body.
`
`4.
`
`I have never had an application for admission to practice before any court or
`
`administrative body denied.
`
`5. No sanction or contempt citation has been imposed against me by any court
`
`or administrative body.
`
`6.
`
`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.
`
`7.
`
`I will be subject to the USPTO Code of Professional Responsibility set forth
`
`in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R.
`
`§ 11.19(a).
`
`1
`
`Intellectual Venturs Exhibit 2004
`
`
`
`Case IPR2017-01497
`Patent No. 7,067,952
`
`8.
`
`I am an experienced litigation attorney with experience in litigations
`
`involving patent infringement in District Courts throughout the United States
`
`and before the International Trade Commission.
`
`9.
`
`I am particularly familiar with the subject matter at issue in this proceeding,
`
`as well as the parallel proceeding involving U.S. Patent No. 7,067,952 filed
`
`by Patent Owner in the United States International Trade Commission
`
`(Investigation No. 337-TA-1073). I have reviewed the relevant materials for
`
`this matter, including the case pleadings, U.S. Patent No. 7,067,952, the
`
`patent prosecution history, and the Petitioners’ asserted prior art. I also have
`
`a thorough understanding of the grounds of unpatentability asserted in the
`
`Petition.
`
`10. 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 are 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 and that such willful false statements may jeopardize the outcome of
`
`this proceeding.
`
`2
`
`Intellectual Venturs Exhibit 2004
`
`
`
`Dated: March 12, 2018
`
`Case IPR2017-01497
`Patent No. 7,067,952
`
`Patrick T. Driscoll
`Mintz, Levin, Cohn, Ferris, Glovsky
`and Popeo, P.C.
`One Financial Center
`Boston, MA 02111
`Telephone: (617) 348-3055
`Facsimile: (617) 542-2241
`ptdriscoll@mintz.com
`
`3
`
`Intellectual Venturs Exhibit 2004
`
`
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