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