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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SHENZHEN ZHIYI TECHNOLOGY CO. LTD., D/B/A/ ILIFE,
`Petitioner,
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`v.
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`IROBOT CORPORATION,
`Patent Owner.
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`Case No.: IPR2017-02061
`Patent 6,809,490
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`AFFIDAVIT OF NICHOLAS A. BROWN
`IN SUPPORT OF MOTION FOR PRO HAC VICE ADMISSION
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`Exhibit 1012
`IPR2017-02061
`I, Nicholas A. Brown, am more than twenty-one years of age, am
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`1.
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`competent to present this affidavit, and have personal knowledge of the facts
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`below.
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`2.
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`3.
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`4.
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`This affidavit supports Petitioner’s motion for pro hac vice admission.
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`I am an associate at the law firm Greenberg Traurig, LLP.
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`I have been a litigating attorney for twenty years. I have been
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`litigating patent cases for twenty years.
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`5.
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`I am a member in good standing in the bar of California, and am
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`admitted to practice before the several U.S. District Courts, the U.S. Court of
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`Appeals for the Federal Circuit, and the U.S. Court of Appeals for the Ninth
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`Circuit. I have never been suspended or disbarred from practice before any court or
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`administrative body.
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`6.
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`No court or administrative body has ever denied my application for
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`admission to practice before it.
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`7.
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`No court or administrative body has ever imposed sanctions or
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`contempt citations on me.
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`8.
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`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 the C.F.R.
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`9.
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`I agree
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`to be subject
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`to
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`the USPTO Code of Professional
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`Responsibility set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction
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`Exhibit 1012
`IPR2017-02061
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`under 37 C.F.R. § 11.19(a).
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`10.
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`In the past three years, I have applied for and been granted pro hac
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`vice admission in four proceedings: IPR2015-01983, IPR2015-01984, IPR2015-
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`01985, and IPR2017-02137. Otherwise, I have not applied to appear pro hac vice
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`in any other proceedings before the Office in the last three (3) years.
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`11.
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`I have
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`reviewed
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`the patent-at-issue,
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`the Petition, and
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`the
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`accompanying exhibits. I have been actively involved in litigating the patent-at-
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`issue in the parallel proceedings pending before the International Trade
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`Commission: In re Certain Robotic Vacuum Cleaning Devices And Components
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`Thereof Such As Spare Parts, Investigation No. 337-TA-1057, including taking the
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`depositions of inventors and experts and preparing briefing related to the patent-at
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`issue. I have also reviewed various filings from the underlying litigation including
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`the claim construction briefing and Markman Order. Through my experience and
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`analysis of
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`the aforementioned documents,
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`I have acquired substantial
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`understanding of the underlying technological issues at stake in these proceedings.
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`12. My practice focuses on intellectual property issues, and I have an
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`established familiarity with the legal issues involved in these proceedings based on
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`my eighteen years of experience litigating patents.
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`13.
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`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;
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`Exhibit 1012
`IPR2017-02061
`and further that these statements were made with the knowledge that willful false
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`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.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Dated: June 8, 2018
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`/s/ Nicholas A. Brown
`Nicholas A. Brown, Esq.
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`4
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