`Patent No. 8,510,407
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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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`LENOVO HOLDING COMPANY, INC.,
`LENOVO (UNITED STATES) INC., and
`MOTOROLA MOBILITY LLC,
`Petitioners,
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`v.
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`DODOTS LICENSING SOLUTIONS LLC,
`Patent Owner.
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`CASE IPR2019-01279
`Patent No. 8,510,407
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`DECLARATION OF PERRY M. GOLDBERG IN SUPPORT OF
`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
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`Under 37 C.F.R. § 1.68, I, Perry M. Goldberg, attest to the following:
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`1. I am a member in good standing of the California Bar as well as the
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`following Federal Courts:
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`a. United States Court of Appeals for the Federal Circuit;
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`b. United States District Court for the Northern District of California;
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`c. United Stated District Court for the Central District of California.
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`2. I have not been suspended or disbarred from practice before any court or
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`administrative body;
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`3. I have never had an application for admission to practice before any court
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`or administrative body denied;
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`4. I have never had sanctions or contempt citations imposed by any court or
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`administrative body against me;
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`5. I have read and will comply with the Office Patent Trial Practice Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.;
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`6. I will be subject to the USPTO Rules of Professional Conduct set forth in
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`37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. §
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`11.19(a);
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`7. I am currently applying to appear pro hace vice in IPR2019-00988,
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`IPR2019-01278, and IPR2019-01279. I have not applied to appear pro hac vice
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`before the Board in connection with any other proceedings in the last three years.
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`8. I am an experienced litigation attorney and have been involved in
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`numerous patent infringement cases in the U.S. International Trade Commission
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`and in federal District Courts across the country. I have experience in various
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`aspects of patent infringement matters including trials, Markman hearings, and
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`summary judgment hearings.
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`9. I am lead counsel for DoDots in a copending litigation DoDots Licensing
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`Solutions LLC v. Lenovo Holding Company Inc., Case No. 1:18-cv-00098-MN,
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`pending in the United States District Court for the District of Delaware. I have
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`reviewed and am familiar with the asserted patents, the prior art references, and
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`invalidity claim charts in the co-pending litigation. Further, I have been involved
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`and am familiar with the factual and legal arguments at issue in the co-pending
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`litigation. Accordingly, I am familiar with the subject matter at issue in the inter
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`partes review proceedings for the asserted patents.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Respectfully submitted,
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`By: /s/ Perry M. Goldberg
`Perry M. Goldberg
`Progress LLP
`11620 Wilshire Blvd. 9th Floor
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`3
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`Los Angeles, CA 90025
`Phone: (310) 697-7201
`Email: goldberg@progressllp.com
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