`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________
`
`AMERICAN NATIONAL MANUFACTURING INC.,
`Petitioner,
`
`v.
`
`SLEEP NUMBER CORPORATION
`f/k/a SELECT COMFORT CORPORATION,
`Patent Owner.
`____________
`
`Case No. IPR2019-00500
`Patent No. 9,737,154 B2
`____________
`
`DECLARATION OF ELIZABETH A. PATTON IN SUPPORT OF
`MOTION FOR ADMISSION PRO HAC VICE
`
`Sleep Number Corp.
`EXHIBIT 2021
`IPR2019-00500
`Page 1
`
`
`
`Case No. IPR2019-00500
`Patent No. 9,737,154 B2
`
`I, Elizabeth A. Patton, declare as follows:
`
`1.
`
`I am a partner in the business litigation group, with a particular
`
`focus on intellectual property litigation, at Fox Rothschild LLP. I have been
`
`practicing law in the field of intellectual property litigation for over seven
`
`years, and have been specifically practicing patent litigation for the last six
`
`years.
`
`2.
`
`3.
`
`I have been counsel on several patent litigation cases.
`
`I am a member in good standing of the State Bar of Minnesota.
`
`I am admitted to practice before the Minnesota Supreme Court, the U.S.
`
`District Court for the District of Minnesota, and the U.S. District Court for the
`
`Eastern District of Michigan.
`
`4.
`
`I have never been suspended or disbarred from practice before
`
`any court or administrative body.
`
`5.
`
`I have never had an application for admission to practice before
`
`any court or administrative body denied.
`
`6.
`
`I have never had any sanctions or contempt citations imposed
`
`against me by any court or administrative body.
`
`2
`
`Sleep Number Corp.
`EXHIBIT 2021
`IPR2019-00500
`Page 2
`
`
`
`Case No. IPR2019-00500
`Patent No. 9,737,154 B2
`
`7.
`
`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 Title
`
`37 of the C.F.R.
`
`8.
`
`I agree to be subject to the USPTO Code of Professional
`
`Responsibility as set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
`
`jurisdiction under 37 C.F.R. § 11.19(a).
`
`9.
`
`I am a senior member of the team representing Patent Owner in
`
`the following IPR proceedings: IPR2019-00497 (U.S. Pat. No. 8,769,747),
`
`IPR2019-00500 (U.S. Pat. No. 9,737,154), and IPR2019-00514 (U.S. Pat. No.
`
`5,904,172).
`
`10.
`
`I am also a senior member of the team representing Patent Owner
`
`in the following related district court cases: Sleep Number Corporation v.
`
`American National Manufacturing Inc., 5:18-cv-00357(AB)(SPx) (C.D. Cal.
`
`2018) and Sleep Number Corporation v. Sizewise Rentals, LLC, 5:18-cv-
`
`00356(AB)(SPx) (C.D. Cal. 2018).
`
`11.
`
`I am considerably familiar with the subject matter in this
`
`proceeding.
`
`3
`
`Sleep Number Corp.
`EXHIBIT 2021
`IPR2019-00500
`Page 3
`
`
`
`Case No. IPR2019-00500
`Patent No. 9,737,154 B2
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated: September 12, 2019
`
`s/Elizabeth A. Patton
`Elizabeth A. Patton
`Fox Rothschild LLP
`Suite 2000, Campbell Mithun Tower
`222 South Ninth Street
`Minneapolis, MN 55402-3338
`Phone: (612) 607-7000
`Fax: (612) 607-7100
`E-mail: epatton@foxrothschild.com
`
`4
`
`Sleep Number Corp.
`EXHIBIT 2021
`IPR2019-00500
`Page 4
`
`