`OF MOTION TO APPEAR PRO HAC VICE ON BEHALF
`OF PATENT OWNER COREPHOTONICS, LTD.
`
`I, James S. Tsuei do hereby declare:
`
`1.
`
`2.
`
`3.
`
`I am an attorney at the firm of Russ August & Kabat.
`
`I am a member in good standing of the State Bar of California.
`
`I have not 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.
`
`No sanction or contempt citation has been imposed against me by any
`
`court or administrative body.
`
`6.
`
`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
`
`Code of Federal Regulations.
`
`7.
`
`I acknowledge that I will be subject to the U.S. Patent and Trademark
`
`Office Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101, et seq.
`
`and to the Office’s disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`8.
`
`During the last three years, I have applied to appear pro hac vice in the
`
`following proceedings before the Office:
`
`
`
`
`
`1
`
`
`
`Corephotonics Ex. 2011
`Apple v. Corephotonics
`IPR2020-00878
`
`
`
`• Adobe Inc. v. Realtime Adaptive Streaming LLC, Case No. IPR2019-
`
`00712. The Board granted this motion to appear pro hac vice.
`
`• Google LLC v. Realtime Adaptive Streaming LLC, Case No. IPR2019-
`
`01033. The Board granted this motion to appear pro hac vice.
`
`• Google LLC v. Realtime Adaptive Streaming LLC, Case No. IPR2019-
`
`01035. The Board granted this motion to appear pro hac vice.
`
`• Arris Solutions, Inc., v. Realtime Adaptive Streaming LLC, Case No.
`
`IPR2019-01222. The Board granted this motion to appear pro hac vice.
`
`• Samsung Display Co., Ltd., v. Solas OLED, Ltd., Case No. IPR2019-
`
`01668. The Board granted this motion to appear pro hac vice.
`
`• Apple Inc. v. Corephotonics, Ltd., Case No. IPR2020-00487. The Board
`
`granted this motion to appear pro hac vice.
`
`• Apple Inc. v. Corephotonics, Ltd., Case No. IPR2020-00860. The Board
`
`granted this motion to appear pro hac vice.
`
`9.
`
`I am also concurrently applying to appear pro hac vice in the following
`
`proceedings before the Office, which the Board has not yet had the oppor-
`
`tunity to decide my motion to appear:
`
`• Apple Inc. v. Corephotonics, Ltd., Case No. IPR2020-00861
`
`• Apple Inc. v. Corephotonics, Ltd., Case No. IPR2020-00862
`
`
`
`
`
`2
`
`
`
`Corephotonics Ex. 2011
`Apple v. Corephotonics
`IPR2020-00878
`
`
`
`• Apple Inc. v. Corephotonics, Ltd., Case No. IPR2020-00877
`
`• Apple Inc. v. Corephotonics, Ltd., Case No. IPR2020-00896
`
`• Apple Inc. v. Corephotonics, Ltd., Case No. IPR2020-00897
`
`• Apple Inc. v. Corephotonics, Ltd., Case No. IPR2020-00905
`
`• Apple Inc. v. Corephotonics, Ltd., Case No. IPR2020-00906
`
`10.
`
`I am a technically trained and experienced patent litigation attorney. I
`
`have practiced patent litigation since 2012, and have litigated numerous patent
`
`infringement litigation matters in the U.S. district courts.
`
`11.
`
`I represent Patent Owner Corephotonics, Ltd. as an attorney in the
`
`copending litigation in which U.S. Patent No. 10,330,897 is asserted against
`
`Petitioner Apple Inc. I have an established familiarity with the subject matter
`
`in this proceeding as a result of my role in the development and preparation
`
`of claim construction positions and responses to Petitioner’s invalidity de-
`
`fenses, which overlap to a significant extent with the grounds for unpatenta-
`
`bility presented in the Petition for Inter Partes Review in IPR2020-00878.
`
`12.
`
`I 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 that these statements were made with the knowledge that willful, false
`
`
`
`
`
`3
`
`
`
`Corephotonics Ex. 2011
`Apple v. Corephotonics
`IPR2020-00878
`
`
`
`statements and the like so made are punishable by fine or imprisonment, or
`
`both, under 18 U.S.C. § 1001
`
`
`
`Dated: June 2, 2021
`
`
`
` /James S. Tsuei/
`James S. Tsuei
`RUSS AUGUST & KABAT
`12424 Wilshire Boulevard, 12th Floor
`Los Angeles, CA 90025
`Telephone: 310-826-7474
`
`Attorney for Patent Owner,
`COREPHOTONICS, LTD.
`
`
`
`
`
`4
`
`
`
`Corephotonics Ex. 2011
`Apple v. Corephotonics
`IPR2020-00878
`
`
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