`
`__________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`____________________
`
`LKQ Corporation and Keystone Automotive Industries, Inc.,
`
`Petitioners,
`
`v.
`
`GM Global Technology Operations LLC,
`
`Patent Owner.
`
`_________________
`
`Case No.: IPR2020-00534
`U.S. Design Patent No. D797,625 S
`__________________________
`
`
`
`
`
`DECLARATION OF IFTEKHAR A. ZAIM IN SUPPORT OF
`PETITIONER’S UNOPPOSED MOTION
`FOR ADMISSION PRO HAC VICE UNDER 37 C.F.R. § 42.10
`
`
`
`
`
`
`Ex. 1016, LKQ v. GM
`IPR2020-00534
`
`
`
`IPR2020-00534
`U.S. Design Patent No. D797,625 S
`
`I, Iftekhar A. Zaim, declare as follows:
`
`1.
`
`2.
`
`I am an associate at the law firm Irwin IP LLC.
`
`I am a member in good standing of the Illinois State Bar (admitted on
`
`May 1, 2014).
`
`3.
`
`I have never been suspended or disbarred from practice before any court
`
`or administrative body.
`
`4.
`
`I have never had an application for admission to practice before any
`
`court or administrative body denied.
`
`5.
`
`I have had no sanctions or contempt citations imposed against me by
`
`any court or administrative body.
`
`6.
`
`I have read and will comply with the Office Patent Trial Guide and the
`
`Board’s Rules of Practice for Trials set forth in part 42 of title 37, Code of Federal
`
`Regulations.
`
`7.
`
`I agree to be subject to the USPTO Rules of Professional Conduct set
`
`forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R.
`
`§ 11.19(a).
`
`8.
`
`I have applied to appear pro hac vice in two other proceeding before
`
`the Office in the last three (3) years: IPR2018-00802, in which my application to
`
`appear pro hac vice was granted, and IPR2020-00064, in which my application to
`
`appear pro hac vice is pending.
`
`2
`
`
`
`IPR2020-00534
`U.S. Design Patent No. D797,625 S
`
`
`9.
`
`I am an experienced litigating attorney with almost five years’
`
`experience in private law practice as an intellectual property litigator, including
`
`substantial experience with patent litigation. I have experience with dispositive
`
`motion practice as well as fact and expert discovery. I have been substantially
`
`involved in more than eight patent cases and proceedings, including cases before
`
`various United States District Courts and the United States International Trade
`
`Commission. I have also been substantially involved in numerous other non-patent
`
`cases before United States District Courts and the United States Court of
`
`International Trade. Finally, as alluded above, I also served as counsel pro hac vice
`
`in a previous inter partes review proceeding before the Board, IPR2018-00802, and
`
`served as first chair at oral argument in that proceeding.
`
`10.
`
`I am familiar with the subject matter and patent, U.S. Design Patent No.
`
`D797,625 S (“the ’625 Patent”), at issue in this proceeding, including its prosecution
`
`history and the technical field to which the ’625 Patent is addressed. In particular, I
`
`have been a member of the legal team advising the Petitioner in the instant IPR
`
`proceeding and related proceedings since September of 2020 and worked with
`
`Petitioner’s expert consultants. I have thereby developed a thorough understanding
`
`of the ’625 Patent, the relevant art, and the technical field.
`
`
`
`3
`
`
`
`IPR2020-00534
`U.S. Design Patent No. D797,625 S
`
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true;
`
`and further that these statements are made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`
`
`
`
`Dated: October 16, 2020
`
`By:
`
`/Iftekhar A. Zaim/
`
`
`
`
`
`
`
`
`
`
`
`Iftekhar A. Zaim
`IRWIN IP LLC
`Telephone: (312) 667-6092
`222 South Riverside Plaza, Suite 2350
`Chicago, Illinois 60606
`izaim@irwinip.com
`
`
`
`
`
`
`4
`
`
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