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`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`INTEL CORP., CAVIUM LLC, and DELL INC.,
`Petitioners,
`
`v .
`
`ALACRITECH, INC.,
`Patent Owner.
`____________
`
`Case No. IPR2018-002341
`Patent 8,805,948 B2
`
`
`
`
`AMENDED DECLARATION OF BRADY COX
`IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
`
`
`
`1
`Cavium LLC (formerly Cavium, Inc.), which filed a Petition in Case
`IPR2018-00403, and Dell Inc. which filed a Petition in Case IPR2018-01307, have
`been joined as petitioners in this proceeding
`
`
`
`
`
`DELL EX. 1505.1
`
`
`
`IPR2018-00226
`Patent 7,124,205 B2
`
`I, Brady Cox, hereby declare under penalty of perjury:
`
`1.
`
`I am an attorney with the law firm of Alston & Bird LLP and practice
`
`in its IP Litigation group. I have been a practicing attorney since 2010, primarily
`
`in the area of patent litigation.
`
`2.
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`I hold a B.S. degree in physics from Brigham Young University and a
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`J.D. Degree from the University of Virginia School of Law.
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`3.
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`4.
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`I am a member in good standing of the Bar of the State of Texas.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
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`5.
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`I have never been denied admission to practice before any court or
`
`administrative body.
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`6.
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`I have never been subject to sanctions or contempt citations imposed
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`by any court or administrative body.
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`7.
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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, as set forth in title 37, part 42
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`of the Code of Federal Regulations (C.F.R.).
`
`8.
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`I agree to be subject to the United States Patent and Trademark Office
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`Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and the
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`Office’s disciplinary jurisdiction under 37 C.F.R.§ 11.19(a).
`
`9.
`
`I have appeared pro hac vice in one other proceeding before the
`
`
`
`- 2 -
`
`
`
`
`DELL EX. 1505.2
`
`
`
`IPR2018-00226
`Patent 7,124,205 B2
`
`United States Patent and Trademark Office in the past three (3) years, in:
`
`
`
`Itron, Inc. v. Smart Meter Technologies, Inc. IPR2017-01199
`(directed to U.S. Patent No. 7,058,524)
`
`10.
`
`I also submitted a motion for pro hac vice admission in the following
`
`IPR which is related to challenges of another patent owned by Alacritech,
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`IPR2018-00226 (directed to U.S. Patent No. 7,124,205 B2). That motion was
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`provisionally granted subject to my filing an amended declaration indicating that I
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`would be subject to the Office’s Rules of Professional Conduct set for in 37 C.F.R.
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`§§ 11.101 et seq.
`
`11.
`
`I am an experienced litigating attorney and have specific experience in
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`patent law and patent law litigation. I have represented clients in numerous patent
`
`infringement lawsuits across the country involving patents in a variety of technical
`
`areas,
`
`including computer networking, mechanical engineering, electrical
`
`engineering, telecommunications, and computer science.
`
`12.
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`I have an established familiarity with the subject matter at issue in this
`
`proceeding. In addition to my general familiarity with the technologies identified
`
`in the challenged patent, I represented Dell in district court litigation involving the
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`challenged patent and its family members, where I reviewed the challenged patents
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`and their file histories, prepared invalidity contentions, corresponded with subject
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`matter experts, and participated in depositions with the challenged patents’ listed
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`inventors. I have reviewed each of the challenged patents, the Petitions, and the
`- 3 -
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`
`
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`
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`DELL EX. 1505.3
`
`
`
`IPR2018-00226
`Patent 7,124,205 B2
`
`accompanying exhibits, as well as the challenged patents’ prosecution history. I
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`am also knowledgeable about the prior art related to the challenged patents, as
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`addressed in the Petitions. As a result of my involvement in the district court
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`litigation, as well as my investigation of the challenged patent, its prosecution
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`history, and the prior art, I have acquired substantial understanding of the
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`technology at issue in this IPR. I have also reviewed all of the publicly available
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`briefs and other filings associated with this IPR.
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`Pursuant to 28 U.S.C. § 1746, I declare under penalty of perjury that the
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`foregoing is true and correct and that all statements made herein of my own
`
`knowledge are true and that all opinions expressed herein are my own; and further
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`that these statements were made with the knowledge that willful false statements
`
`and the like are punishable by fine or imprisonment, or both, under Section 1001 of
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`Title 18 of the United States Code and that such willful false statements may
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`jeopardize the validity of the application or any patent issued thereon.
`
`/ Brady Cox /
`Brady Cox
`
`
`
`
`
`March 4, 2019
`Date
`
`
`
`- 4 -
`
`
`
`
`DELL EX. 1505.4
`
`
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