UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`UNIFIED PATENTS INC.,
`Petitioner,
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner.
`
`____________________
`
`Case IPR2018-00952
`Patent No. 9,253,239
`____________________
`
`DECLARATION OF MICHAEL N. ZACHARY IN SUPPORT OF
`PATENT OWNER’S PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. §42.10(c)
`
`1
`
`Bradium Exhibit 2003
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`UNIFIED PATENTS INC.,
`Petitioner,
`
`v.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner.
`
`____________________
`
`Case IPR2018-00952
`Patent No. 9,253,239
`____________________
`
`DECLARATION OF MICHAEL N. ZACHARY IN SUPPORT OF
`PATENT OWNER’S PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. §42.10(c)
`
`1
`
`Bradium Exhibit 2003
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`
`
`
`I, MICHAEL N. ZACHARY, declare as follows:
`
`1.
`
`I am a partner at the law firm of Bunsow De Mory LLP, located at
`
`701 El Camino Real, Redwood City, CA 94063, which has been retained by
`
`Patent Owner Bradium Technologies LLC in this inter partes review.
`
`2.
`
`I make this declaration in support of the Patent Owner’s application
`
`for my admission pro hac vice.
`
`3.
`
`I am a member in good standing of the state Bars in California,
`
`Oregon, and Washington State. I am also duly admitted and authorized to
`
`practice law before the U.S. District Court for the Central District of California,
`
`U.S. District Court for the Eastern District of California, U.S. District Court for
`
`the Northern District of California, U.S. District Court for the Southern District of
`
`California, U.S. District Court for the District of Colorado, U.S. District Court for
`
`the District of Oregon, U.S. District Court for the Eastern District of Texas, U.S.
`
`District Court for the Eastern District of Washington, and U.S. District Court for
`
`the Western District of Washington.
`
`4.
`
`I have not had any application denied for admission to practice, nor
`
`have I been sanctioned, cited for contempt, suspended or disbarred from practice,
`
`before any court or administrative body.
`
`5.
`
`If admitted pro hac vice in this matter, I will serve as counsel with
`2
`
`Bradium Exhibit 2003
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`
`
`
`Chris J. Coulson, also of the law firm Bunsow De Mory LLP. Mr. Coulson is
`
`lead counsel on this case and is registered to practice in this Court.
`
`6.
`
`I understand that, upon admission pro hac vice, I will be subject to
`
`the USPTO Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et
`
`seq. and to disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`7.
`
`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 the C.F.R.
`
`8.
`
`I hereby agree to notify the Court immediately of any matter
`
`affecting my standing at the bar of any other Court.
`
`9.
`
`I have appeared pro hac vice in the matters Microsoft Corp. v.
`
`Bradium Techs. LLC, IPR2015-01432; Microsoft Corp. v. Bradium Techs. LLC,
`
`IPR2015-01434; Microsoft Corp. v. Bradium Techs. LLC, IPR2015-01435;
`
`Microsoft Corp. v. Bradium Techs. LLC, 2016-00448; Microsoft Corp. v.
`
`Bradium Techs. LLC, IPR2016-00449; Microsoft Corp. v. Bradium Techs. LLC,
`
`2016-01897; Prism Pharma Co., Ltd., v. Choongwae Pharma Corp., IPR2014-
`
`00315; Apple Inc., v. Limestone Memory Systems LLC, IPR2016-01561; Apple
`
`Inc., v. Limestone Memory Systems LLC, IPR2016-01567.
`
`10.
`
`I have also appeared pro hac vice in the matters Samsung
`
`Electronics Co., Ltd., et al. v. Image Processing Technologies, LLC, IPR2017-
`
`00336; Samsung Electronics Co., Ltd., et al. v. Image Processing Technologies,
`3
`
`Bradium Exhibit 2003
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`
`
`
`LLC, IPR2017-00347; Samsung Electronics Co., Ltd., et al. v. Image Processing
`
`Technologies, LLC, IPR2017-00353; Samsung Electronics Co., Ltd., et al. v.
`
`Image Processing Technologies, LLC, IPR2017-00355; Samsung Electronics Co.,
`
`Ltd., et al. v. Image Processing Technologies, LLC, IPR2017-00357; Samsung
`
`Electronics Co., Ltd., et al. v. Image Processing Technologies, LLC, IPR2017-
`
`01190; Samsung Electronics Co., Ltd., et al. v. Image Processing Technologies,
`
`LLC, IPR2017-01218.
`
`11.
`
`I have an established familiarity with the subject matter at issue in
`
`this proceeding, having represented Patent Owner in prior inter partes reviews for
`
`the patent at issue in this proceeding, U.S. Pat. 9,253,239 and for related patents. I
`
`have also represented Patent Owner in litigation (now concluded) regarding to
`
`U.S. Pat 9,253,239 and related patents.
`
`12.
`
`I hereby respectfully request that the PTAB grant Patent Owner
`
`Bradium Technologies LLC’s application to permit me to appear and
`
`participate pro hac vice in this case.
`
`13.
`
`I understand that willful false statements and the like are punishable
`
`by fine or imprisonment, or both, under 18 U.S.C. § 1001, and may jeopardize the
`
`validity of the application or any patent issuing thereon. I declare under penalty of
`
`perjury that the foregoing is true and correct.
`
`4
`
`Bradium Exhibit 2003
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`
`
`
`Executed on August 8, 2018
`
`/s/ Michael N. Zachary
`Michael N. Zachary
`
`5
`
`Bradium Exhibit 2003
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
