UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`GOPRO, INC., GARMIN INTERNATIONAL, INC., GARMIN USA, INC.
`Petitioners,
`
`v.
`
`CELLSPIN SOFT, INC.
`
`Patent Owner.
`
`
`
`Case No. IPR2019-01108
`U.S. Patent No. 9,258,698
`
`
`DECLARATION OF KARINEH KHACHATOURIAN IN SUPPORT OF
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION
`
`
`
`
`
`
`
`
`
`
`GoPro/Garmin
`EX. 1022, Page 1
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`GOPRO, INC., GARMIN INTERNATIONAL, INC., GARMIN USA, INC.
`Petitioners,
`
`v.
`
`CELLSPIN SOFT, INC.
`
`Patent Owner.
`
`
`
`Case No. IPR2019-01108
`U.S. Patent No. 9,258,698
`
`
`DECLARATION OF KARINEH KHACHATOURIAN IN SUPPORT OF
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION
`
`
`
`
`
`
`
`
`
`
`GoPro/Garmin
`EX. 1022, Page 1
`
`
`
`I, Karineh Khachatourian, declare the following:
`
`Case No. IPR2019-01108
`U.S. Patent No. 9,258,698
`
`
`1.
`
` I am a partner in the law firm of Rimon P.C., working as the
`
`managing partner of the firm’s office in Palo Alto, California.
`
`2.
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`I am a member in good standing of the California Bar.
`
`3. My California Bar member number is 202634.
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`4.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
`
`5.
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`I have never had a court or administrative body deny my application
`
`for admission to practice.
`
`6.
`
`I have never had any court or administrative body impose sanctions or
`
`contempt citations against me.
`
`7.
`
`I have applied to appear pro hac vice in the following Patent Trial and
`
`Appeal Board (“PTAB”), or United States Patent and Trademark Office
`
`(“USPTO”), proceedings in at least the last three years: IPR2015-01078, IPR2015-
`
`01080, IPR2017-01070, IPR2017-01071, IPR2017-01391, IPR2017-01392,
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`IPR2017-01393, IPR2017-01405, IPR2017-01406, IPR2017-01409, IPR2017-
`
`01410, IPR2018-00401, and IPR2019-01107.
`
`8.
`
`I have read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials, as set forth in Part 42 of Title
`
`37 of the C.F.R.
`
`
`
`1
`
`GoPro/Garmin
`EX. 1022, Page 2
`
`
`
`Case No. IPR2019-01108
`U.S. Patent No. 9,258,698
`
`I agree to be subject to the United States Patent and Trademark Office
`
`9.
`
`Code of Professional Responsibility set forth in 37 C.F.R. §§ 10.20 et seq., the
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`Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq., and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`10.
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`I am an experienced litigation attorney, with over twenty years of
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`experience in many patent infringement litigations in District Courts across the
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`country, including experience with fact and expert document and deposition
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`discovery, claim construction, Markman hearings, motion practice, and trials and
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`hearings. I have represented Petitioner GoPro, Inc. (“GoPro” or “Petitioner”) in
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`patent litigation and IPR matters for approximately six years.
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`11.
`
`I have been lead counsel for Petitioner GoPro, Inc. in the ongoing
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`litigation captioned Cellspin Soft, Inc., v. GoPro Inc., Case No. 4:17-cv-05939
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`(N.D. Cal.) (filed Mar. 2, 2018) (“the co-pending litigation”) since its inception
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`and have been actively involved in all aspects of the co-pending litigation, which
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`relates to and involves the same patent at issue in this proceeding. I am familiar
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`with the subject matter of the claimed invention and was involved in a validity
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`challenge at the district court level based on 35 U.S.C. § 101 (“Section 101”). I
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`have also been involved in Cellspin’s appeal of the district court order invalidating
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`the patent at issue based on Section 101. Moreover, Petitioner has hired me to
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`represent it in this Petition because of my litigation and PTAB experience. I also
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`
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`2
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`GoPro/Garmin
`EX. 1022, Page 3
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`
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`participated in the preparation of GoPro’s Petition, and I am familiar with the prior
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`Case No. IPR2019-01108
`U.S. Patent No. 9,258,698
`
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`art references based on that preparation.
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`12. Attached as Exhibit A is a true and correct copy of an email exchange
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`I had with John Edmonds, counsel for Patent Owner, wherein he stated that
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`Cellspin does not oppose my application.
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`13.
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`I hereby declare that all statements herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true;
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`and further that these statements are made with the knowledge that willful false
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`statements and the like are punishable by fine, imprisonment, or both, under
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`Section 1001 of Title 18 of the United States Code.
`
`Dated: July 15, 2019
`
`
`
`
`Respectfully Submitted,
`/ Karineh Khachatourian /
`Karineh Khachatourian
`Rimon, P.C.
`2479 E. Bayshore Rd. Suite 210
`Palo Alto, CA 94304
`Telephone: (650) 223-7785
`Fax: (650) 223-7785
`
`
`
`3
`
`GoPro/Garmin
`EX. 1022, Page 4
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`
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`
`
`EXHIBIT A
`
`EXHIBIT A
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`GoPro/Garmin
`EX. 1022, Page 5
`
`
`
`From:
`Sent:
`To:
`Cc:
`Subject:
`
`John Edmonds <jedmonds@ip-lit.com>
`Tuesday, July 9, 2019 7:20 AM
`Karineh Khachatourian; PTO-Edmonds; Steve Schlather; vpearce@orrick.com
`David Xue; Jennifer Bailey
`RE: IPR2019-01108
`
`Karineh,
`
`Cellspin does not oppose.
`
`Regards,
`
`John Edmonds
`713.364.5291
`jedmonds@ip-lit.com
`
`From: Karineh Khachatourian <karinehk@rimonlaw.com>
`Sent: Monday, July 8, 2019 04:24 PM
`To: John Edmonds <jedmonds@ip‐lit.com>; PTO‐Edmonds <pto‐edmonds@ip‐lit.com>; Steve Schlather <sschlather@ip‐
`lit.com>; vpearce@orrick.com
`Cc: David Xue <david.xue@rimonlaw.com>; Jennifer Bailey <jennifer.bailey@eriseip.com>
`Subject: IPR2019‐01108
`
`Hello:
`
`We plan on filing my pro hac vice application in the Panasonic IPR. I presume there is no opposition, but please let me
`know if I am mistaken. Thank you.
`
`1
`
`GoPro/Garmin
`EX. 1022, Page 6
`
`
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