`
`Doug G. Muehlhauser (Reg. No. 42,018)
`William H. Shreve (Reg. No. 35,678)
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`2040 Main Street, Fourteenth Floor
`Irvine, CA 92614
`Tel.:
`(949) 760-0404
`Fax:
`(949) 760-9502
`E-mail: BoxNomadix@knobbe.com
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`GUEST TEK INTERACTIVE ENTERTAINMENT LTD.,
`Petitioner,
`
`v.
`
`NOMADIX, INC.,
`Patent Owner.
`
`Case IPR2019-00253
`Patent 8,626,922
`
`DECLARATION OF MARK LEZAMA IN SUPPORT OF MOTION TO
`APPEAR PRO HAC VICE ON BEHALF OF PATENT OWNER NOMADIX
`
`NOMADIX 2007
`Guest Tek v. Nomadix
`IPR2019-00253
`
`
`
`I, Mark Lezama, do hereby declare:
`
`1.
`
`I am a partner in the law firm of Knobbe, Martens, Olson & Bear, LLP.
`
`Lead counsel in this inter partes review proceeding is Douglas G. Muehlhauser, who
`
`is also a partner in the law firm of Knobbe, Martens, Olson & Bear, LLP.
`
`Mr. Muehlhauser is registered to practice before the United States Patent and
`
`Trademark Office and holds Registration No. 42,018. With respect to this
`
`proceeding, I will work closely with Mr. Muehlhauser.
`
`2.
`
`3.
`
`I have approximately twelve years of experience as a patent litigator.
`
`I am counsel with whom Patent Owner is familiar. Patent Owner
`
`desires, and has a need, to be represented in these proceedings by counsel with whom
`
`it is familiar.
`
`4.
`
`I am comfortable and experienced with technically and legally complex
`
`matters, such as will be present in this proceeding. In particular, I am experienced
`
`with technically and legally complex matters in the field of bandwidth management.
`
`In addition, I hold a Bachelor of Science degree in mathematics from Harvard
`
`College.
`
`5.
`
`I am familiar with U.S. Patent 8,626,922 (“the ’922 patent”), and with
`
`the legal subject matter, technical subject matter, and prior art discussed in
`
`Petitioner’s request for inter partes review of the ’922 patent, which forms the basis
`
`for this proceeding.
`
`- 1 -
`
`NOMADIX 2007
`Guest Tek v. Nomadix
`IPR2019-00253
`
`
`
`6.
`
`7.
`
`I am a member in good standing of the Bar of the State of California.
`
`I have never been suspended or disbarred from practice before any court
`
`or administrative body.
`
`8.
`
`I have never had a court or administrative body deny my application for
`
`admission to practice.
`
`9.
`
`I have never been sanctioned or cited for contempt by any court or
`
`administrative body.
`
`10.
`
`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 the C.F.R.
`
`11.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`Code of Professional Responsibility set forth in 37 C.F.R. §§ 11.101 et seq. and
`
`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`12.
`
`I appeared pro hac vice in Amazon.com, Inc. and Amazon Web Services,
`
`LLC v. Personalized Media Communications, LLC, Case No. IPR2014-01528, an
`
`order for which the Board granted on May 19, 2015. In the past four years, I have
`
`not appeared pro hac vice in any other proceedings before the United States Patent
`
`and Trademark Office.
`
`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; and
`
`further that these statements were made with the knowledge that willful, false
`
`- 2 -
`
`NOMADIX 2007
`Guest Tek v. Nomadix
`IPR2019-00253
`
`
`
`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. 8,626,922.
`
`Dated: November 11, 2019
`
`By:
`
`Mark Lezama
`
`31188542
`
`- 3 -
`
`NOMADIX 2007
`Guest Tek v. Nomadix
`IPR2019-00253
`
`