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`Filed: April 5, 2019
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________________
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`GOOGLE LLC,
`Petitioner
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`v.
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`CYWEE GROUP LTD.
`Patent Owner
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`____________________
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`Case IPR2018-01257
`Patent No. 8,552,978
`____________________
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`DECLARATION OF CECIL E. KEY
`IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
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`I, Cecil E. Key, declare as follows:
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`1. My name is Cecil E. Key, and my professional address is 1750
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`Tysons Blvd., Suite 1500, Tysons Corner, Virginia. I am over the age of 18,
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`and I make this declaration based on my personal knowledge.
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`2.
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`I am an attorney
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`licensed and admitted
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`to practice
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`in
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`the
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`Commonwealth of Virginia, and the District of Columbia, where I have been
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`admitted since 1996 and 1997, respectively. I am a member in good standing of
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`both the Virginia Bar and the Bar of the District of Columbia. I practice in the
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`field of intellectual property, including patent litigation, and have done so for over
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`twenty (20) years.
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`3.
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`I am admitted to practice before the Courts of Appeal for the First,
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`Fourth and Federal Circuits, the United States District Courts for the Eastern
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`District of Virginia, the District of Columbia, the Eastern District of Texas, the
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`District of Colorado, and all state courts in Virginia and the District of Columbia.
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`I have also been admitted to practice and have appeared pro hac vice before,
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`among others, the United States District Courts for the District of Massachusetts,
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`the Southern and Western Districts of New York, the Southern District of
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`California, the District of Maryland, the District of Delaware and the Western
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`District of Texas.
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`4.
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`I have also appeared before the United States International Trade
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`Commission, and have practiced and continue to practice regarding trademark
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`matters before the United States Patent and Trademark Office, and the
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`Trademark Trial and Appeal Board.
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`5.
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`I am a member of the American Bar Association and the
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`American Intellectual Property Law Association.
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`6.
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`I have extensive experience in litigating patent infringement
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`matters. I have been litigating patent infringement cases since my admission
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`to the bar in 1996. I have served as lead counsel in such cases, including cases
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`in the Eastern District of Texas, the District of Colorado, and the District of
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`Delaware, and have appeared before the Court of Appeals for the Federal
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`Circuit numerous times regarding appeals in patent infringement cases.
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`7.
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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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`8.
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`I have never had a court or administrative body deny my
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`application for admission to practice.
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`9.
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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 Part 42 of
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`the C.F.R.
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`10.
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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 seq.
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`and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`11.
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`I have previously been granted admission pro hac vice in the
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`matter of Salesforce.com, Inc. v. VirtualAgility Inc., CBM2013-00024 and
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`participated in trial in that matter before the Patent Trial and Appeal Board. I
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`have also previously been granted admission pro hac vice in the matter of
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`Unified Patents Inc., v. Vilox Technologies LLC, IPR2018-00044. I have not
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`applied to appear pro hac vice before the Office in any other proceeding in the
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`last three (3) years.
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`12.
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`I have read and am familiar with the patent at issue in this
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`proceeding and its file history, as well as the prior art and other arguments that
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`have been asserted by petitioner.
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`13.
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`I declare, under penalty of perjury pursuant to 28 U.S.C. § 1746,
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`that all statements made herein of my knowledge are true and that all
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`statements made on information and belief are believed to be true.
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`Dated: April 5, 2019
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`Respectfully submitted,
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`/s/ Cecil E. Key
`Cecil E. Key
`DiMuroGinsberg PC - DGKEYIP GROUP
`1750 Tysons Blvd., Suite 1500
`Vienna, Virginia 22102
`Telephone: (703) 289-5118
`Fax: (703) 388-0648
`Email: ckey@dimuro.com
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