`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`Panasonic Corporation of North America et al.,
`Petitioners
`v.
`Cellspin Soft, Inc.
`Patent Owner.
`____________
`Case IPR2019-00131
`Patent 9,258,698
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`DECLARATION OF DAVID MEDINA
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`1.
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`I, David Medina, am competent to present this declaration, and have
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`personal knowledge of the facts set forth herein.
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`2. This declaration is given in support of Petitioners Panasonic
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`Corporation of North America and Panasonic Corporation’s (collectively,
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`“PANASONIC”) Motion for Pro Hac Vice Admission of David Medina.
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`3.
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`I am an associate at the law firm of Orrick, Herrington & Sutcliffe
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`LLP. I am an experienced litigating attorney. I have over four years of experience
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`in intellectual property law, focusing on patent litigation matters as an associate in
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`Orrick’s Intellectual Property Group and as an attorney with Panasonic
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`Corporation.
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`4.
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`I am familiar with the subject matter at issue in this proceeding. I
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`assisted with the preparation of the petition for inter partes review in this matter
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`and I have continued to work on this inter partes review proceeding since then, as
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`well as the co-pending district court and Federal Circuit litigation involving the
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`’698 Patent. Over the course of that period, I have become very familiar with the
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`’698 Patent, its file history, and the references asserted as prior art by
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`PANASONIC in this IPR proceeding.
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`5.
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`6.
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`I am a member in good standing of the State Bar of California.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
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`1
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`7. No court or administrative body has ever denied my application for
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`admission to practice before it.
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`8. No court or administrative body has ever imposed sanctions or
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`contempt citations on me.
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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 set forth in Part 42 of Section 37
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`of the C.F.R.
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`10. I understand that I will be subject to the United States Patent and
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`Trademark Office Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101
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`et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`11. I have not applied to appear pro hac vice in any other proceeding
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`before the Office in the last three (3) years.
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`12. 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 are
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`believed to be true; and further that these statements were made with the
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`knowledge that willful false statements and the like so made are punishable by fine
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`or imprisonment or both under 18 U.S.C. 1001.
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`Dated: November 5, 2019
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`/David Medina/
`David Medina
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`2
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`CERTIFICATION OF SERVICE (37 C.F.R. § 42.6(e))
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`The undersigned hereby certifies that the above-captioned
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`“DECLARATION OF DAVID MEDINA” was served in its entirety on
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`November 5, 2019, upon the following parties via electronic service:
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`John J. Edmonds
`Edmonds & Schlather, PLLC
`355 South Grand Avenue, Suite 2450
`Los Angeles, CA 90071
`pto-edmonds@ip-lit.com
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`Stephen F. Schlather
`Edmonds & Schlather, PLLC
`1616 South Voss Road, Suite 125
`Houston, TX 77057
`sschlather@ip-lit.com
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`Attorneys for Patent Owner Cellspin Soft, Inc.
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`By: /Karen Johnson/
` Karen Johnson
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`3
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