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`Filed on behalf of: KVK-Tech, Inc.
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`Filed January 24, 2019
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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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`______________________
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`KVK-Tech, Inc.
`Petitioner
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`v.
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`Shire PLC
`Patent Owner
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`______________________
`Case IPR2018-00290
`U.S. Pat. No. 8,846,100
`______________________
`DECLARATION OF DAVID J. GALLUZZO IN SUPPORT OF
`MOTION FOR ADMISSION PRO HAC VICE
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`I, David J. Galluzzo, declare as follows:
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`1.
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`I was admitted to the Connecticut Bar in 2006. I have been practicing law for over
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`12 years. For more than 8 years my practice has focused primarily on patent litigation.
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`2.
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`3.
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`Over the course of my career, I have been counsel in over 10 patent litigations.
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`I am a member in good standing of the Bars of New York and Connecticut, and
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`am admitted to practice before the U.S. District Courts for the Southern District of New York,
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`Eastern District of New York, and the District of Delaware. My Connecticut Bar membership
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`number is 426165 and my New York Bar membership number is 4495503.
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`4.
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`I have never been suspended or disbarred from practice before any court or
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`administrative body.
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`5.
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`I have never had a court or administrative body deny my application for
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`admission to practice.
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`6.
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`I have read and will comply with the Patent Office Trial Practice Guide and the
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`Board’s Rules for Practice for Trials, as set forth in 37 C.F.R. Part 42.
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`7.
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`I agree to be subject to the United States Patent and Trademark Office Rules of
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`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under
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`37 C.F.R. § 11.19(a).
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`8.
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`I have currently applied to appear pro hac vice in the following related proceeding
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`before the United States Patent and Trademark Office IPR2017-00293. I have not applied to
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`appear pro hac vice before the United States Patent and Trademark Office in any other
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`proceedings in the last three years.
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`9.
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`I am intimately familiar with the subject matter of U.S. Patent No. 8,846,100. I
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`am also intimately familiar with amphetamine salt formulations, such as Adderall XR® as a
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`result of my preparation and research in this matter. I have represented a number of life sciences
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`and pharmaceutical companies in patent litigation matters before Federal district courts. In
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`addition, I am a former pharmaceutical scientist with close to ten years of chemistry experience.
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`The technology in these disputes included pharmaceutical compounds and method-of-treatment
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`claims.
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`10.
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`I hereby declare that all statements made herein of my own knowledge are true
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`and that all statements made on information and belief are believed to be true; and further that
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`these statements and the like are punishable by fine, imprisonment, or both under Section 1001
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`of Title 18 of the United States Code.
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`Date: January 24, 2019
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`Respectfully submitted,
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`By: /s/ David J. Galluzzo
` David J. Galluzzo
` Lucas & Mercanti, LLP
` 30 Broad Street
` New York, New York 10004
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`
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