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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 IPR2019-00236
`Patent No. 7,868,912
`
`DECLARATION OF MICHAEL W. DE VRIES IN SUPPORT OF
`UNOPPOSED MOTION TO APPEAR PRO HAC VICE ON BEHALF OF
`PATENT OWNER AVIGILON FORTRESS CORPORATION
`
`
`
`
`
`
`
`
`
`
`AVIGILON EX. 2001
`IPR2019-00236
`Page 1 of 6
`
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`
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`I, Michael W. De Vries, do hereby declare:
`1.
`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
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`work closely with Mr. Goryunov.
`
`2.
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`I hold a Bachelor of Arts degree in Political Science and English from the
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`University of California at Berkley. I hold a Juris Doctor degree from the
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`University of California, Berkeley School of Law, and hold a Certificate in
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`Law and Technology from the Berkeley Center for Law & Technology.
`
`3.
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`I have more than 17 years of experience as a litigation attorney who
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`specializes in patent litigation and represents clients in patent litigation
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`matters in various United States District Courts, the Court of Appeals for the
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`Federal Circuit, and before the International Trade Commission. My
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`experience includes several matters related to computer systems and
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`networked communications technologies, and I have particular experience
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`relevant to the technological and legal matters at issue in this proceeding. I
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`am, therefore, an experienced patent litigation attorney with particular
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`expertise that is pertinent to this proceeding. Avigilon Fortress Corporation
`
`AVIGILON EX. 2001
`IPR2019-00236
`Page 2 of 6
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`(“Avigilon”) desires, and have a need, to be represented in certain aspects of
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`these proceedings by an experienced patent litigation attorney who has
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`particular expertise that is relevant to the issues in this proceeding.
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`
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`4.
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`I have also led efforts to educate attorneys at Kirkland & Ellis LLP about the
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`Inter Partes Review procedures and have participated in preparing multiple
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`Inter Partes Review petitions.
`
`5.
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`I am very familiar with U.S. Patent No. 7,868,912, and with the legal
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`subject matter, technical subject matter, and prior art discussed in
`
`Avigilon’s Request for Inter Partes Review of U.S. Patent No. 7,868,912,
`
`which forms the basis for this proceeding.
`
`6.
`
`I am a member in good standing of the Bar of the State of California. I am
`
`admitted to practice before the United States District Court for the Eastern
`
`District of Texas, the United States District Court for the Eastern District of
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`California, the United States District Court for the Eastern District of
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`California, the United States District Court for the Northern District of
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`California, the United States District Court for the Central District of
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`California, the United States District Court for the Southern District of
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`California, the United States District Court of Colorado, the United States
`
`District Court for the Eastern District of Michigan, the United States Court of
`
`AVIGILON EX. 2001
`IPR2019-00236
`Page 3 of 6
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`
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`Appeals for the Federal Circuit, and the United States Court of Appeals for
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`
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`the Eleventh Circuit.
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`7.
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`I have never been suspended or disbarred from practice before any court or
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`administrative body.
`
`8.
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`I have never had a court or administrative body deny my application for
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`admission to practice.
`
`9.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
`
`10.
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`I have read and will comply with the Office Patent Trial Practice Guide and
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`the Board's Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
`
`11.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq.
`
`and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`12.
`
`In the past 3 years, I was admitted pro hac vice as counsel for 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
`AVIGILON EX. 2001
`IPR2019-00236
`Page 4 of 6
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`•
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` •
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`Firewalls, respectively.
`
`
`
`Inter Partes Reviews IPR2016-01398, IPR2016-01401, and IPR2016-01402
`as counsel for Intel Corp. concerning Security Processor With Bus
`Configuration, Performance Based Packet Ordering In A PCI Express Bus,
`and Method For Effecting The Controlled Shutdown Of Data Processing
`Units, respectively.
`
`Inter Partes Review IPR2016-01434 as counsel for Oracle Corporation
`concerning an Apparatus For Distributing Content Objects To A Personalized
`Access Point Of A User Over A Network-Based Environment And Method.
`
`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.
`
`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 Reviews IPR2017-02183, IPR2018-00128, IPR2018-00176 as
`counsel for Motorola Solutions, Inc. concerning 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.
`
` •
`
`
`
` •
`
`
`
` •
`
`
`
` •
`
`
`
`•
`
`•
`
`13.
`
`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;
`AVIGILON EX. 2001
`IPR2019-00236
`Page 5 of 6
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`and further that these statements were made with the knowledge that willful,
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`false statements and the like so made are punishable by fine or
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`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/ Michael W. De Vries
`Michael W. De Vries, P.C.
`KIRKLAND & ELLIS LLP
`333 South Hope St.
`Los Angeles, CA 90071
`Telephone: 213-680-8400
`Facsimile: 213-680-8500
`michael.devries@kirkland.com
`
`
`AVIGILON EX. 2001
`IPR2019-00236
`Page 6 of 6
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