`____________________
`
`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.
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`I am a partner at the law firm of Bunsow De Mory LLP, located at
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`701 El Camino Real, Redwood City, CA 94063, which has been retained by
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`Patent Owner Bradium Technologies LLC in this inter partes review.
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`2.
`
`I make this declaration in support of the Patent Owner’s application
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`for my admission pro hac vice.
`
`3.
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`I am a member in good standing of the state Bars in California,
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`Oregon, and Washington State. I am also duly admitted and authorized to
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`practice law before the U.S. District Court for the Central District of California,
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`U.S. District Court for the Eastern District of California, U.S. District Court for
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`the Northern District of California, U.S. District Court for the Southern District of
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`California, U.S. District Court for the District of Colorado, U.S. District Court for
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`the District of Oregon, U.S. District Court for the Eastern District of Texas, U.S.
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`District Court for the Eastern District of Washington, and U.S. District Court for
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`the Western District of Washington.
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`4.
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`I have not had any application denied for admission to practice, nor
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`have I been sanctioned, cited for contempt, suspended or disbarred from practice,
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`before any court or administrative body.
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`5.
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`If admitted pro hac vice in this matter, I will serve as counsel with
`2
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`Bradium Exhibit 2003
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`
`
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`Chris J. Coulson, also of the law firm Bunsow De Mory LLP. Mr. Coulson is
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`lead counsel on this case and is registered to practice in this Court.
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`6.
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`I understand that, upon admission pro hac vice, I will be subject to
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`the USPTO Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et
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`seq. and to disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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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 set forth in part 42 of the C.F.R.
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`8.
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`I hereby agree to notify the Court immediately of any matter
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`affecting my standing at the bar of any other Court.
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`9.
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`I have appeared pro hac vice in the matters Microsoft Corp. v.
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`Bradium Techs. LLC, IPR2015-01432; Microsoft Corp. v. Bradium Techs. LLC,
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`IPR2015-01434; Microsoft Corp. v. Bradium Techs. LLC, IPR2015-01435;
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`Microsoft Corp. v. Bradium Techs. LLC, 2016-00448; Microsoft Corp. v.
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`Bradium Techs. LLC, IPR2016-00449; Microsoft Corp. v. Bradium Techs. LLC,
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`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.
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`I have also appeared pro hac vice in the matters Samsung
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`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
`
`
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`LLC, IPR2017-00347; Samsung Electronics Co., Ltd., et al. v. Image Processing
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`Technologies, LLC, IPR2017-00353; Samsung Electronics Co., Ltd., et al. v.
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`Image Processing Technologies, LLC, IPR2017-00355; Samsung Electronics Co.,
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`Ltd., et al. v. Image Processing Technologies, LLC, IPR2017-00357; Samsung
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`Electronics Co., Ltd., et al. v. Image Processing Technologies, LLC, IPR2017-
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`01190; Samsung Electronics Co., Ltd., et al. v. Image Processing Technologies,
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`LLC, IPR2017-01218.
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`11.
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`I have an established familiarity with the subject matter at issue in
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`this proceeding, having represented Patent Owner in prior inter partes reviews for
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`the patent at issue in this proceeding, U.S. Pat. 9,253,239 and for related patents. I
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`have also represented Patent Owner in litigation (now concluded) regarding to
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`U.S. Pat 9,253,239 and related patents.
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`12.
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`I hereby respectfully request that the PTAB grant Patent Owner
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`Bradium Technologies LLC’s application to permit me to appear and
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`participate pro hac vice in this case.
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`13.
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`I understand that willful false statements and the like are punishable
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`by fine or imprisonment, or both, under 18 U.S.C. § 1001, and may jeopardize the
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`validity of the application or any patent issuing thereon. I declare under penalty of
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`perjury that the foregoing is true and correct.
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`4
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`Bradium Exhibit 2003
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
`
`
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`Executed on August 8, 2018
`
`/s/ Michael N. Zachary
`Michael N. Zachary
`
`5
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`Bradium Exhibit 2003
`Unified Patents Inc. v. Bradium Technologies LLC
`IPR2018-00952
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`