UNITED STATES PATENT AND TRADEMARK OFFICE
`___________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`HEWLETT PACKARD ENTERPRISE COMPANY,
`Petitioner,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`Patent Owner.
`___________
`Case No. IPR2019-00033
`Patent No. 8,902,760
`___________
`
`DECLARATION OF KARON N. FOWLER IN SUPPORT OF
`PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF KARON N. FOWLER
`PURSUANT TO 37 C.F.R. § 42.10
`
`HPE 1047-0001
`
`HPE Co. v. ChriMar Sys., Inc.
`IPR 2019-00033 - U.S. Patent No. 8,902,760
`
`
`___________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`HEWLETT PACKARD ENTERPRISE COMPANY,
`Petitioner,
`
`v.
`
`CHRIMAR SYSTEMS, INC.,
`Patent Owner.
`___________
`Case No. IPR2019-00033
`Patent No. 8,902,760
`___________
`
`DECLARATION OF KARON N. FOWLER IN SUPPORT OF
`PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF KARON N. FOWLER
`PURSUANT TO 37 C.F.R. § 42.10
`
`HPE 1047-0001
`
`HPE Co. v. ChriMar Sys., Inc.
`IPR 2019-00033 - U.S. Patent No. 8,902,760
`
`
`
`I, Karon N. Fowler, declare as follows:
`
`1.
`
`I am an associate at Morgan, Lewis & Bockius LLP (“Morgan
`
`Lewis”). I joined Morgan Lewis as an intellectual property litigation associate in
`
`2016 after serving as a judicial law clerk for the Honorable Eduardo C. Robreno in
`
`the U.S. District Court of the Eastern District of Pennsylvania.
`
`2.
`
`Since joining Morgan Lewis, I have primarily focused my practice on
`
`patent litigation. In that time, I have gained experience conducting technical
`
`infringement and validity analysis, working with technical experts to prepare
`
`reports on infringement and validity issues, preparing for depositions of technical
`
`experts and fact witnesses, briefing claim construction issues, preparing for
`
`Markman hearings, drafting dispositive motions on a range of technical issues, and
`
`representing clients in patent litigation trials and hearings before district courts
`
`around the country, arbitral panels, and the International Trade Commission.
`
`Further, I have assisted my colleagues at Morgan Lewis in proceedings before the
`
`Patent Trial & Appeal Board, and I am familiar with its established practices.
`
`3.
`
`I am a member in good standing of the California State Bar (Bar No.
`
`308145). I am also admitted to practice in the United States Court of Appeals for
`
`the Federal Circuit, the United States Court of Appeals for the Ninth Circuit, and
`
`the United States District Courts for the Central, Eastern, Northern, and Southern
`
`Districts of California.
`
`HPE 1047-0002
`
`
`
`4.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body. No application of mine for admission to practice
`
`before any court or administrated body has ever been denied. No court or
`
`administrative body has imposed sanctions or contempt citations against me.
`
`5.
`
`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 37 C.F.R.
`
`I acknowledge and agree that I will be subject to the USPTO Code of Professional
`
`Responsibility set forth in 37 C.F.R. §§ 11.101 et seq., and to disciplinary
`
`jurisdiction under 37 C.F.R. §11.19(a).
`
`6.
`
`I have not applied for pro hac vice admission before the Office in any
`
`other proceeding during the past three years. I am concurrently applying for pro
`
`hac vice admission in the following IPR proceedings: IPR2019-00032 and
`
`IPR2019-00033.
`
`7.
`
`I have established familiarity with the subject matter at issue this
`
`proceeding. I have reviewed in detail and am familiar with U.S. Patent No.
`
`8,902,760 and all exhibits relied upon by Petitioner in this proceeding. I also
`
`participated in drafting the Petition in this proceeding. Moreover, I have engaged
`
`and will continue to engage in extensive strategic and substantive discussions
`
`regarding this proceeding with Hersh Mehta, who is a registered practitioner and
`
`the lead counsel for Petitioner in this proceeding.
`
`3
`
`HPE 1047-0003
`
`
`
`8.
`
`In addition to the foregoing, I have gained experience with a range of
`
`network communication technologies as a patent litigator. For example, I have
`
`been involved in district court matters concerning computer network activity
`
`monitors (Packet Intelligence LLC v. NetScout Systems, Inc., No. 2:16-CV-230-
`
`JRG (E.D. Tex.)), fax-to-e-mail communication systems via data network
`
`(OpenPrint LLC v. HP Inc., 1:17-cv-01077-GMS (D. Del.)), and serial data
`
`communication technology for movable barrier operators (Certain Access Control
`
`Systems And Components Thereof, Inv. No. 337-TA-1016 (U.S.I.T.C.)).
`
`9.
`
`I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that these statements are made with the knowledge
`
`that willful false statements and the like so made are punishable by fine or
`
`imprisonment, or both, under Section 1001 of Title 18 of the United States Code.
`
`10.
`
`I executed this declaration on October 26, 2018, in Palo Alto,
`
`California.
`
`Dated: October 26, 2018
`
`By: /Karon N. Fowler/
`Karon N. Fowler
`
`4
`
`HPE 1047-0004
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on October 26,
`2018, a complete and entire copy of DECLARATION OF KARON N.
`FOWLER IN SUPPORT OF PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF KARON N. FOWLER PURSUANT TO 37 C.F.R. §
`42.10, was served on all Patent Owner’s counsel of record via electronic mail as
`follows:
`
`LEAD COUNSEL
`Frank A. Angileri (Reg. No. 36,733)
`BROOKS KUSHMAN P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`Telephone (248) 358-4400
`Facsimile (248) 358-3351
`fangileri@brookskushman.com
`CHRMC0123IPR1@brookskushman.com
`
`BACK-UP COUNSEL
`Thomas A. Lewry (Reg. No. 30,770)
`Marc Lorelli (Reg. No. 43,759)
`Christopher C. Smith
`(Reg. No.
`59,669)
`BROOKS KUSHMAN P.C.
`1000 Town Center, 22nd Floor
`Southfield, MI 48075
`Telephone (248) 358-4400
`Facsimile (248) 358-3351
`tlewry@brookskushman.com
`mlorelli@brookskushman.com
`csmith@brookskushman.com
`
`Dated: October 26, 2018
`
`/Hersh H. Mehta/
`Hersh H. Mehta (Reg. No. 62,336)
`
`5
`
`HPE 1047-0005
`
`
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