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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
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`CANON, INC., CANON U.S.A., INC., AND AXIS COMMUNICATIONS AB,
`Petitioners,
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`v.
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`AVIGILON FORTRESS CORPORATION,
`Patent Owner.
`______________________
`
`Case No. IPR2019-00311
`Patent No. 7,932,923
`______________________
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`DECLARATION OF ADAM R. ALPER 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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`AVIGILON EX. 2002
`IPR2019-00311
`Page 1 of 5
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`1.
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`I, Adam R. Alper, do hereby declare:
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`I am a partner in the law firm Kirkland & Ellis LLP. Lead counsel in this inter
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`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 Arts degree in Economics from Stanford University. I hold
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`a Juris Doctor degree from the University of Arizona, James E. Rogers School
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`of Law.
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`3.
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`I have more than 18 years of experience as a litigation attorney who specializes
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`in patent litigation and represents 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 many
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`matters in the electrical and computer science arts, and I have particular
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`experience relevant to the technological and legal matters at issue in this
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`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. 2002
`IPR2019-00311
`Page 2 of 5
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`4.
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`I am very familiar with U.S. Patent No. 7,932,923, 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. 7,932,923, 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. I am
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`admitted to practice before the U.S. District Court for the Northern District of
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`California, the U.S. Court of Appeals for the Ninth Circuit, the U.S. Court of
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`Appeals for the Federal Circuit, the U.S. District Court for the Central District of
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`California, the U.S. District Court for the Western District of Wisconsin, the U.S.
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`Court Of Appeals For The Third Circuit, and the U.S. District Court for the Eastern
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`District Of Texas (Pro Hac Vice).
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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.
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`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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`AVIGILON EX. 2002
`IPR2019-00311
`Page 3 of 5
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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:
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`• 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.
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`AVIGILON EX. 2002
`IPR2019-00311
`Page 4 of 5
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`• 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
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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. 7,932,923.
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`Date: January 9, 2019
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`Respectfully submitted,
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` /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
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`AVIGILON EX. 2002
`IPR2019-00311
`Page 5 of 5
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