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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`AXIS COMMUNICATIONS AB, CANON, INC., AND CANON U.S.A., INC.,
`Petitioners,
`
`v.
`
`AVIGILON FORTRESS CORPORATION,
`Patent Owner.
`______________________
`
`Case No. IPR2019-00236
`Patent No. 7,868,912
`______________________
`
`DECLARATION OF ADAM R. ALPER IN SUPPORT OF UNOPPOSED
`MOTION TO APPEAR PRO HAC VICE ON BEHALF OF PATENT
`OWNER AVIGILON FORTRESS CORPORATION
`
`.
`
`
`
`
`
`
`
`
`
`
`AVIGILON EX. 2002
`IPR2019-00236
`Page 1 of 5
`
`
`
`
`
`
`
`
`1.
`
`I, Adam R. Alper, do hereby declare:
`
`I am a partner in the law firm Kirkland & Ellis LLP. Lead counsel in this inter
`
`partes review proceeding is Eugene Goryunov, who is a partner in the law firm
`
`Kirkland & Ellis LLP, and is registered to practice before the PTO and holds
`
`Registration No. 61,579. With respect to this proceeding, I will work closely
`
`with Mr. Goryunov.
`
`2.
`
`I hold a Bachelor of Arts degree in Economics from Stanford University. I hold
`
`a Juris Doctor degree from the University of Arizona, James E. Rogers School
`
`of Law.
`
`3.
`
`I have more than 18 years of experience as a litigation attorney who specializes
`
`in patent litigation and represents clients in patent litigation matters in various
`
`United States District Courts, the Court of Appeals for the Federal Circuit, and
`
`before the International Trade Commission. My experience includes many
`
`matters in the electrical and computer science arts, and I have particular
`
`experience relevant to the technological and legal matters at issue in this
`
`proceeding. I am, therefore, an experienced patent litigation attorney with
`
`particular expertise that is pertinent to this proceeding. Avigilon Fortress
`
`Corporation (“Avigilon”) desires, and has a need, to be represented in certain
`
`aspects of these proceedings by an experienced patent litigation attorney who
`
`has particular expertise that is relevant to the issues in this proceeding.
`AVIGILON EX. 2002
`IPR2019-00236
`Page 2 of 5
`
`
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`
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`4.
`
`I am very familiar with U.S. Patent No. 7,868,912, and with the legal subject
`
`matter, technical subject matter, and prior art discussed in Petitioner’s Request
`
`for Inter Partes Review of U.S. Patent No. 7,868,912, which forms the basis for
`
`this proceeding.
`
`5.
`
`I am a member in good standing of the Bar of the State of California. I am
`
`admitted to practice before the U.S. District Court for the Northern District of
`
`California, the U.S. Court of Appeals for the Ninth Circuit, the U.S. Court of
`
`Appeals for the Federal Circuit, the U.S. District Court for the Central District of
`
`California, the U.S. District Court for the Western District of Wisconsin, the U.S.
`
`Court Of Appeals For The Third Circuit, and the U.S. District Court for the Eastern
`
`District Of Texas (Pro Hac Vice).
`
`6.
`
`I have never been suspended or disbarred from practice before any court or
`
`administrative body.
`
`7.
`
`I have never had a court or administrative body deny my application for
`
`admission to practice.
`
`8.
`
`I have never been sanctioned or cited for contempt by any court or
`
`administrative body.
`
`9.
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`I have read and will comply with the Office Patent Trial Practice Guide and the
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`Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
`
`AVIGILON EX. 2002
`IPR2019-00236
`Page 3 of 5
`
`
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`
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`10. I agree to be subject to the United States Patent and Trademark Office Rules of
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`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a).
`
`11. In the past four years, I was admitted pro hac vice as counsel before the PTAB
`
`in the following actions:
`
`• Inter Partes Reviews IPR2014-01457, IPR2014-01458, IPR2014-01459,
`IPR2015-01052, IPR2015-01053, and IPR2015-01054 as counsel for Biscotti
`concerning a Real Time Video Communications System.
`• Inter Partes Reviews IPR2015-00999 and IPR2015-01001 as counsel for
`Cisco Systems, Inc. concerning Admissions Control In A Connectionless
`Communications Network, and Providing Media Communication Across
`Firewalls, respectively.
`• Inter Partes Reviews IPR2016-00589, IPR2016-00590, IPR2016-00591, and
`IPR2016-00592 as counsel for Eagle View Technologies, Inc. concerning
`Concurrent Display Systems And Methods For Aerial Roof Estimation, Pitch
`Determination Systems And Methods For Aerial Roof Estimation, and
`Concurrent Display Systems And Methods For Aerial Roof Estimation,
`respectively.
`• Inter Partes Reviews IPR2016-00593 and IPR2016-00594 as counsel for
`Pictometry International Corp. concerning Systems And Methods For
`Processing Images With Edge Detection And Snap-To Feature And System
`and Process For Roof Measurement Using Aerial Imagery, respectively.
`• Inter Partes Review IPR2016-01402 as counsel for Intel Corp. concerning a
`Method For Effecting The Controlled Shutdown Of Data Processing Units.
`• Inter Partes Review IPR2017-00609; IPR2017-00610; and IPR2017-00616 as
`counsel for LivePerson, Inc. concerning Integrated Chat Client With Calling
`Party Choice; Interaction Management; And Method and Apparatus for
`Intelligent Routing of Incoming Calls to Representatives in a Call Center,
`respectively.
`
`AVIGILON EX. 2002
`IPR2019-00236
`Page 4 of 5
`
`
`
`
`
`• Inter Partes Review IPR2018-00320 as counsel for Sierra Wireless, Inc.
`concerning Method and Devices for the Transmission of Data with
`Transmission Error Checking.
`• Inter Partes Review IPR2017-02183, IPR2018-00128, IPR2018-00176 as
`counsel for Motorola Solutions, Inc. concerning a Method of Efficiently
`Synchronizing to a Desired Timeslot in a Time Division Multiple Access
`Communication System.
`• Inter Partes Review IPR2018-01268 as counsel for Avigilon Patent Holding 1
`Corp. concerning a Method and System for Programmable Camera for
`Configurable Security and Surveillance Systems.
`12. I 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
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`further that these statements were 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 and that such willful
`
`false statements may jeopardize the validity of U.S. Patent No. 7,868,912.
`
`Date: January 9, 2019
`
`
`
`
`
`
`Respectfully submitted,
`
` /s/ Adam R. Alper/
`Adam R. Alper, P.C.
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94194
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`adam.alper@kirkland.com
`
`
`AVIGILON EX. 2002
`IPR2019-00236
`Page 5 of 5
`
`
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