`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`
`APPLE, INC.,
`
`Petitioner
`
`v.
`
`UUSI, LLC d/b/a NARTRON,
`
`Patent Owner.
`
`____________________
`
`
`Cases IPR2019-00355; IPR2019-00356; IPR2019-00357; IPR2019-
`00358; IPR2019-00359; and IPR2019-00360
`
`Patent No. 5,796,183
`
`____________________
`
`
`EXHIBIT 2001
`DECLARATION OF LAWRENCE M. HADLEY IN SUPPORT OF
`PATENT OWNER'S MOTION FOR PRO HAC VICE ADMISSION
`
`
`
`1579606
`
`
`
`
`
`Cases IPR2019-00355; 356; 357; 358; 359; 360
`Patent No. 5,796,183
`
`I, Lawrence M. Hadley, declare as follows:
`1. My name is Lawrence M. Hadley, and my professional address is
`Glaser Weil Fink Howard Avchen & Shapiro LLP, 10250 Constellation Blvd., 19th
`Floor, Los Angeles, CA 90067. I am over the age of 18, and I make this
`declaration in support of the patent owner’s motion for my pro hac vice admission
`based on my personal knowledge.
`2.
`I am an attorney licensed and admitted to practice in the State of
`California, where I have been admitted since 1992. I am a member in good
`standing of the California State Bar.
`3.
`I practice in the field of intellectual property, including patent
`litigation, and have done so for over twenty-five (25) years.
`4.
`I am admitted to practice before all state courts in California, the U.S.
`Supreme Court, the Courts of Appeal for the Ninth and Federal Circuits, the United
`States International Trade Commission, and numerous federal district courts across
`the country, including all federal district courts in California.
`5.
`I have extensive experience in litigating patent infringement matters.
`I have been litigating patent infringement cases since 1993 and have served as lead
`trial counsel in dozens of patent infringement cases. I also have argued more than
`ten appeals of patent cases at the Federal Circuit, including appeals of IPR Final
`Written Decisions.
`6.
`I am familiar with the subject matter of this proceeding. I am lead
`trial counsel for UUSI in the underlying district court action against Apple
`involving U.S. Pat. No. 5,796,183 (the “’183 Patent”), UUSI, LLC, d/b/a Nartron
`v. Apple Inc., Civ. Action No. 18-cv-04637- JD (N.D. Cal.). I also am lead trial
`counsel for UUSI in a district court action against Samsung involving the ’183
`Patent, UUSI, LLC, d/b/a Nartron v. Samsung Electronics Co., Ltd., Civ. Action
`No. 1:15-cv-00146-JTN (W.D. Mich.). Finally, I am lead appellate counsel for
`
`1579606
`
`
`
`
`
`Cases IPR2019-00355; 356; 357; 358; 359; 360
`Patent No. 5,796,183
`
`UUSI in Samsung’s Federal Circuit appeal of the recently-concluded IPR filed by
`Samsung, which found that Samsung had not met its burden of proving the
`challenged claims of the ’183 patent invalid as obvious. Samsung v. UUSI, LLC
`d/b/a/ Nartron, AIA Review No. IPR2016-00908, Final Written Decision dated
`Oct. 18, 2017, appealed in Samsung Electronics Co., Ltd. v. UUSI, LLC, No. 2018-
`1310, pending at the Federal Circuit.
`7.
`During the course of these actions, I have become highly familiar with
`the invention claimed in the ’183 Patent, the technology relevant to the ’183 patent,
`the prosecution history of the ’183 patent, including the two reexamination
`proceedings, the prior art to the ’183 patent, including the prior art asserted in the
`six new IPRs filed by Apple, the prior Samsung IPR challenge to the same claims
`of the ’183 patent at issue in these new IPRs, the Board’s Final Written Decision in
`that IPR, and the arguments concerning the validity of the patent made by
`petitioner.
`8.
`I have never been suspended, disbarred, sanctioned or cited for
`contempt by any court or administrative body.
`9.
`I have never had a court or administrative body deny my application
`for admission to practice.
`10.
`I have read and agree to be subject to the Office Patent Trial Practice
`Guide and 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’s Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et. seq.
`and submit to disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`12.
`I have not applied to appear pro hac vice before the Office in any
`other proceeding in the last three (3) years.
`13. The underlying action was originally filed in the Western District of
`Michigan and later transferred to the Northern District of California. Since
`
`1579606
`
`
`
`
`
`Cases IPR2019-00355; 356; 357; 358; 359; 360
`Patent No. 5,796,183
`
`transfer, the parties have stipulated, and the court has ordered, a stay of
`proceedings until the pending appeal of the Board’s decision in the Samsung IPR
`involving the same claims (AIA Review No. IPR2016- 00908, Final Written
`Decision dated Oct. 18, 2017) is decided. Apple has not yet produced confidential
`information in the underlying litigation and will not do so unless and until the stay
`is lifted.
`14. UUSI’s lead counsel, Joseph A. Rhoa, is a registered practitioner and
`his registration number is 37,515.
`15.
`I declare, under penalty of perjury pursuant to 28 U.S.C. § 1746, that
`all statements made herein of my knowledge are true and that all statements made
`on information and belief are believed to be true.
`
`
`Respectfully submitted,
`By: /s/ Lawrence M. Hadley
` Lawrence M Hadley
`GLASER WEIL FINK HOWARD
` AVCHEN & SHAPIRO LLP
`10250 Constellation Blvd., 19th Flr.
`Los Angeles, California 90067
`Phone: 310-553-3000
`Fax: 310-556-2920
`lhadley@glaserweil.com
`
`
`
`
`
`
`Dated: March 22, 2019
`
`
`
`
`1579606
`
`
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