`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Filed: June 28, 2019
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`GOOGLE LLC,
`Petitioner
`
`v.
`
`CYWEE GROUP LTD.
`Patent Owner
`
`____________________
`
`Case IPR2018-01258 (Patent No. 8,441,438)
`Case IPR2018-01257 (Patent No. 8,552,978)
`
`____________________
`
`
`
`DECLARATION OF MICHAEL W. SHORE
`IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
`
`
`
`
`
`
`
`I, Michael W. Shore, declare as follows:
`
`1.
`
`I am more than twenty-one years of age, competent to present
`
`this affidavit, and have personal knowledge of the facts set forth herein.
`
`2.
`
`3.
`
`I am a partner at the law firm of Shore Chan DePumpo LLP.
`
`I have been litigating patent cases for twenty years.
`
`4. My experience in patent litigation matters includes being lead counsel
`
`in multiple trials, arguing multiple Markman hearings, and many other patent-
`
`related hearings concerning various issues, such as validity and infringement.
`
`5.
`
`I am a member in good standing of the Bar of Texas (admitted 1990),
`
`as well as the following Federal Courts: U.S. District Court for the Eastern
`
`District of Texas, U.S. District Court for the Northern District of Texas, U.S.
`
`District Court for the Southern District of Texas, U.S. District Court for the
`
`Western District of Texas, U.S District Court for New Mexico, Fifth Circuit
`
`Court of Appeals, United States Court of Appeals for the Federal Circuit, U.S.
`
`District Court for the Eastern District of Arkansas, U.S. District Court for the
`
`Western District of Arkansas, U.S. District Court for the Central District of
`
`California, U.S. District Court for the Southern District of California, U.S.
`
`District Court for the Northern District of California, U.S. District Court for the
`
`District of Delaware, U.S. District Court for the Northern District of Florida, U.S.
`
`District Court for the District of Massachusetts, U.S. District Court for the
`
`2
`
`
`
`
`
`Southern District of New York and U.S. District Court for the Northern District
`
`of New York.
`
`6.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`7.
`
`No court or administrative body has ever denied my application for
`
`admission to practice before it.
`
`8.
`
`No court or administrative body has imposed sanctions or contempt
`
`citations related to my conduct in my 26-year legal career other than one instance
`
`where I was instructed not to send opposing counsel emails for a limited period
`
`during a hotly contested trial due to the Court's belief that prior emails were not
`
`professional in tone. I do not believe this instruction qualifies as a "sanction" but
`
`include this disclosure nonetheless. If this incident is of concern to the Board, I
`
`am willing to provide a copy of the emails and the transcript of the Court's
`
`instruction during trial.
`
`9.
`
`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 in 37 C.F.R. § 42.
`
`10.
`
`I understand that I will be subject to the USPTO Code of Professional
`
`Responsibility set forth in 37 C.F.R. §§ 10.20 et seq. and disciplinary jurisdiction
`
`under 37 C.F.R. § 11.19(a).
`
`11.
`
`I have previously been granted admission pro hac vice in Mylan
`
`3
`
`
`
`
`
`Pharmaceuticals Inc. v. St. Regis Mohawk Tribe et al., IPR2016-01127, IPR2016-
`
`01128, IPR2016-01129, IPR2016-01130, IPR2016-01131, and IPR2016-01132. I
`
`have not applied to appear pro hac vice before the Office in any other proceeding
`
`in the last three (3) years.
`
`12.
`
`I currently represent Patent Owner, CyWee Group Ltd. in several
`
`district court proceedings as lead counsel, including: CyWee Group, Ltd. v.
`
`Google LLC, 1:18-cv-00571-RGA (D. Del.); CyWee Group, Ltd. v. HTC
`
`Corporation and HTC America, Inc., 2:17-cv-00932-JLR (W.D. Wash.); CyWee
`
`Group Ltd. v. LG Electronics, Inc., et al., No. 3:17-cv-01102 (S.D. Cal); CyWee
`
`Group, Ltd. v. Huawei Device Co., Ltd., Huawei Device (Dongguan) Co., Ltd.
`
`and Huawei Device USA, Inc., 2:17-cv-00495-WCB-RSP (E.D. Tex.); CyWee
`
`Group, Ltd. v. ZTE (USA), Inc., 3:17-cv-02130-BEN-RBB (S.D. Cal.); CyWee
`
`Group, Ltd. v. Motorola Mobility LLC, 1:17-cv-00780-RGA (D. Del.); and
`
`CyWee Group, Ltd. v. Samsung Electronics Co. Ltd. and Samsung Electronics
`
`America, Inc., 2:17-cv-00140-WCB-RSP (E.D. Tex.).
`
`13.
`
`I am familiar with the subject matter of U.S. Patent Nos. 8,441,438
`
`and 8,552,978, including their prosecution histories, as well as alleged prior art
`
`and arguments that have been asserted by Petitioner.
`
`14.
`
`I hereby declare that all statements made herein of my own
`
`knowledge are true and further that all statements herein are made with
`
`4
`
`
`
`
`
`knowledge that willful false statements and the like are punishable by fine or
`
`imprisonment, or both, under Section 1001 of Title 18 of the United States Code.
`
`
`Dated: June 25, 2019
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Michael W. Shore
`Michael W. Shore
`
`
`
`
`
`
`
`
`
`5
`
`
`
`
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
