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