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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 AKSHAY S. DEORAS IN SUPPORT OF
`UNOPPOSED MOTION TO APPEAR PRO HAC VICE ON BEHALF OF
`PATENT OWNER AVIGILON FORTRESS CORPORATION
`
`
`
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`
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`
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`
`
`AVIGILON EX. 2003
`IPR2019-00236
`Page 1 of 4
`
`
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`
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`I, Akshay S. Deoras, 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
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`Kirkland & Ellis LLP, and is registered to practice before the PTO and holds
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`Registration No. 61,579. With respect to this proceeding, I will work closely
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`with Mr. Goryunov.
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`2.
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`I hold a Bachelor of Science degree in Electrical Engineering from Columbia
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`University. I hold a Juris Doctor degree from the Columbia University School of
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`Law.
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`3.
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`I have more than 9 years of experience as a litigation attorney who specializes in
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`patent litigation and representing clients in patent litigation matters in various
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`United States District Courts, the Court of Appeals for the Federal Circuit, and
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`before the International Trade Commission. My experience includes several
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`matters in the electrical, computer science, and chemical arts, and I have
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`particular experience relevant to the technological and legal matters at issue in
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`this proceeding. I am, therefore, an experienced patent litigation attorney with
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`particular expertise that is pertinent to this proceeding. Avigilon Fortress
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`Corporation (“Avigilon”) desires, and has a need, to be represented in certain
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`aspects of these proceedings by an experienced patent litigation attorney who
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`has particular expertise that is relevant to the issues in this proceeding.
`AVIGILON EX. 2003
`IPR2019-00236
`Page 2 of 4
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`4.
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`I am very familiar with U.S. Patent No. 7,868,912, and with the legal subject
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`matter, technical subject matter, and prior art discussed in Petitioner’s Request
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`for Inter Partes Review of U.S. Patent No. 7,868,912, which forms the basis for
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`this proceeding.
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`5.
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`I am a member in good standing of the Bar of the State of California and the State
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`of New York. I am admitted to practice before the U.S. District Court for the
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`Northern District of California and the U.S. Court of Appeals for the Federal Circuit.
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`6.
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`I have never been suspended or disbarred from practice before any court or
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`administrative body.
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`7.
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`I have never had a court or administrative body deny my application for
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`admission to practice.
`
`8.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
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`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.
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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).
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`11. In the past four years, I was admitted pro hac vice as counsel before the PTAB
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`in the following actions:
`
`AVIGILON EX. 2003
`IPR2019-00236
`Page 3 of 4
`
`
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`
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`• Inter Partes Review IPR2016-01402 as counsel for Intel Corporation
`concerning a Method For Effecting The Controlled Shutdown Of Data
`Processing Units.
`• 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
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`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
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code and that such willful
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`false statements may jeopardize the validity of U.S. Patent No. 7,868,912.
`
`Date: January 9, 2019
`
`
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`
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`Respectfully submitted,
`
` /s/ Akshay S. Deoras/
`Akshay S. Deoras
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94194
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`akshay.deoras@kirkland.com
`
`
`AVIGILON EX. 2003
`IPR2019-00236
`Page 4 of 4
`
`
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