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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________________________
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`VESTAS-AMERICAN WIND TECHNOLOGY, INC. and
`VESTAS WIND SYSTEMS A/S,
`Petitioner,
`v.
`GENERAL ELECTRIC CO.,
`Patent Owner.
`_____________________________________
`
`Case IPR2018-01015
`Patent 7,629,705
`____________________________________
`
`
`DECLARATION OF LOUIS W. TOMPROS IN SUPPORT OF
`MOTION FOR ADMISSION PRO HAC VICE
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`GE 2021
`Vestas v. GE
`IPR2018-01015
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`I, Louis Tompros, declare as follows:
`1.
`I am a partner at the law firm of Wilmer Cutler Pickering Hale
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`and Dorr LLP in Boston, Massachusetts.
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`2.
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`I have been practicing law for approximately fifteen years. My
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`practice during much of that time has focused on intellectual property
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`litigation, and particularly, patent litigation.
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`3.
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`I am a member in good standing of the Bar of the
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`Commonwealth of Massachusetts, and am admitted to practice before the
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`United States Supreme Court, the Massachusetts Supreme Judicial Court, the
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`United States Courts of Appeal for the First, Seventh, Ninth, and Federal
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`Circuits, and the United States District Courts for the District of
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`Massachusetts and the Eastern District of Michigan.
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`4. My Massachusetts Bar No. is 657791.
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`5.
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`I have represented parties in patent litigation cases in the
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`District of Massachusetts, the Eastern District of Texas, the District of
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`Delaware, the Northern, Central, Eastern, and Southern Districts of
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`California, the District of Minnesota, and the International Trade
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`Commission, among other jurisdictions. Those cases have involved, among
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`other issues, issues involving Patent Office rules, regulations, and
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`procedures, including inventorship disputes, inequitable conduct,
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`prosecution history disclaimer, and other issues for which review of a
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`patent’s prosecution history is critical. See, e.g., General Electric Company
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`v. Wilkins, No. 1:10-cv-00674-LJO-JLT (E.D. Cal.) (involving disputed
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`inventorship); Qualcomm, Inc. v. Broadcom Corporation, No. 3:05-cv-1958
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`(S.D. Cal.) (involving allegations of inequitable conduct).
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`6.
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`I have represented parties in patent appeals to the United States
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`Court of Appeals for the Federal Circuit in more than thirty cases. Several
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`of those cases were appeals from the Patent Trial and Appeal Board (“the
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`Board”)—including In re Thomas G. Packard, No. 13-1204 (PTAB No.
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`12/004,324), and In re Klein, 647 F.3d 1343, No. 2010-1411 (BPAI No.
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`10/2007,747). I was lead counsel in the Klein and Packard cases.
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`7.
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`I have, on pro hac vice admission, represented parties in inter
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`partes reexamination matters before the Board in three matters, Reexam
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`Control Nos. 95/000,580, 95/000,633, and 95/001,272.
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`8.
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`I have, on pro hac vice admission, represented parties in inter
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`partes review matters before the Board in seven maters, Case Nos. IPR2016-
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`00287, IPR2016-00288, IPR2016-00289, IPR2016-00290, IPR2018-01033,
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`IPR2018-01040, and IPR2018-01144. I have also applied to appear pro hac
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`vice in inter partes review matters before the Board in two other matters,
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`Case Nos. IPR2018-01296 and IPR2019-00034.
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`9.
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`I have never been suspended, disbarred, sanctioned or cited for
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`contempt by any court or administrative body.
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`10.
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`I have never had a court deny my application for admission to
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`practice.
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`11. On November 7, 2013, the Patent Office denied my petition to
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`be admitted pro hac vice as backup counsel in inter partes reexamination
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`proceeding Control No. 95/001,272. However, upon a petition for
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`reconsideration, the Board subsequently admitted me pro hac vice in those
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`proceedings in its decision dated December 12, 2013. In addition, on
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`August 9, 2016, the Patent Office denied my motion to be admitted pro hac
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`vice in Case Nos. IPR2016-00287, IPR2016-00288, IPR2016-00289 and
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`IPR2016-00290 for inadvertently omitting averments required by the ’639
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`Order, part 2(b), paragraphs ii and iv. However, upon correction of my
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`declaration in each of those Cases, the Board subsequently admitted me pro
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`hac vice in each Case.
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`12.
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`I have read and will comply with Office Patent Trial Practice
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`guide and the Board’s Rules of Practice for Trials, as set forth in Part 42 of
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`37 C.F.R.
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`13.
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`I agree to be subject to the United States Patent and Trademark
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`Office Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et.
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`seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`14.
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`I am familiar with the subject matter at issue in this proceeding.
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`I participated in the drafting of the Patent Owner’s Preliminary
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`Response (Paper 6) and Patent Owner’s Response (Paper 20) filed in
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`this proceeding, and I have reviewed all other papers filed in this
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`proceeding.
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`15.
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`I have previously represented Patent Owner General Electric
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`Co. (“Patent Owner” or “GE”) in inter partes reexamination No.
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`95/000,633, which also challenged the same U.S. Patent No. 7,629,705 at
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`issue in this proceeding. I have also represented GE in inter partes re-
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`examination No. 95/000,580, which challenged U.S. Patent No. 6,921,985,
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`and in inter partes re-examination No. 95/001,272, which challenged U.S.
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`Patent No. 7,321,221.
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`16.
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief
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`are believed to be true; and further that these statements are made with the
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`knowledge that willful false statements and the like are punishable by fine,
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`imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code.
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`Respectfully Submitted,
`
`/Louis W. Tompros/
`
`Louis W. Tompros
`WILMER CUTLER PICKERING HALE
`AND DORR LLP
`60 State St.
`Boston, MA 02109
`louis.tompros@wilmerhale.com
`Tel.: 627-526-6886
`Fax: 627-526-6000
`
`March 28, 2019
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`6
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