`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`LBT IP I, LLC,
`Patent Owner.
`____________
`
`Case IPR2020-01192
`U.S. Patent No. 8,421,618
`____________
`REVISED DECLARATION OF BRIAN S. SEAL IN SUPPORT OF
`PATENT OWNER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION PURSUANT TO 37 C.F.R. § 42.10(C)
`
`1. My name is Brian S. Seal. I am over 18 years of age and competent to
`
`provide this declaration in support of Patent Owner’s Motion for Pro Hac Vice
`
`Admission.
`
`2. I am a member in good standing of the Bar of the District of Columbia, the
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`U.S. District Court for the District of Columbia, the U.S. Court of Appeals for the
`
`Federal Circuit, and the Supreme Court of the United States.
`
`3. I have never been suspended or disbarred from practicing before any court
`
`or administrative body.
`
`
`
`
`
`
`1
`
`
`LBT IP I LLC EX. 3003
`
`
`
`
`
`
`4. I have never been denied admission to practice before any court or
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`administrative body.
`
`5. No court or administrative body has ever imposed any sanctions or
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`contempt citations against me.
`
`6. I have read and will comply with the Office Patent Trial Practice Guide and
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`the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`7. 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. § 11.19(a).
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`8. I have not applied to appear pro hac vice in any other Office proceedings
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`in the last three years.
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`9. I am an experienced patent litigator. I am a shareholder in the firm of Butzel
`
`Long PC with over 20 years of experience representing clients in patent and
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`technology-related litigation, including matters involving similar technology to that
`
`at issue in this proceeding. I have litigated patent matters through trial and appeal
`
`and have argued complex claim construction and invalidity issues in numerous
`
`district court proceedings.
`
`10. I am also familiar with the specific subject matter of this proceeding. I am
`
`lead counsel for Patent Owner in the related district court litigation on the patent at
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`issue in this inter partes review, U.S. Patent No. 8,421,618 (“’618 Patent”). As such,
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`I have spent considerable time reviewing and analyzing the ’618 Patent.
`
`
`
`
`
`
`2
`
`
`LBT IP I LLC EX. 3003
`
`
`
`
`
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`11. My admission pro hac vice will allow Patent Owner to avoid unnecessary
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`effort and expense in this proceeding.
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`12. The undersigned being hereby warned that willful false statements and
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`the like so made are punishable by fine or imprisonment, or both, under 18 U.S.C.
`
`§1001, and that such willful false statement may jeopardize the validity of this
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`document, declares that he is properly authorized to execute this document on behalf
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`of the owner, and all statements made of his own knowledge are true and all
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`statements made on information and belief are believed to be true.
`
`
`Date: May 19, 2021
`
`
`
`
`
`/s/ Brian S. Seal
`
`
`
`
`
`
`3
`
`
`LBT IP I LLC EX. 3003
`
`
`
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