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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`QUALCOMM INCORPORATED and
`ZYXEL COMMUNICATIONS CORPORATION1,
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`Petitioners,
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`v.
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`UNM RAINFOREST INNOVATIONS,
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`Patent Owner.
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`PTAB Case No. IPR2021-00375
`Patent 8,265,096 B2
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`DECLARATION OF CECIL E. KEY
`IN SUPPORT OF MOTION FOR ADMISSION PRO HAC VICE
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`1 ZyXEL Communications Corporation was joined as a petitioner in this proceeding
`based on a petition and motion for joinder filed in IPR2021-00734, which were
`granted.
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`Ex. 2017 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
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`I, Cecil E. Key, declare as follows:
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`1. My name is Cecil E. Key, and my professional address is 1750 Tysons
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`Blvd., Suite 1500, Tysons Corner, Virginia. I am over the age of 18, and I make this
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`declaration based on my personal knowledge.
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`2.
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`I am an attorney
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`licensed and admitted
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`to practice
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`in
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`the
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`Commonwealth of Virginia, and the District of Columbia, where I have been
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`admitted since 1997 and 1998, respectively. I am a member in good standing of
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`both the Virginia Bar and the Bar of the District of Columbia. I practice in the field
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`of intellectual property, including patent litigation, and have done so for over
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`twenty (20) years.
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`3.
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`I am admitted to practice before the Courts of Appeal for the First,
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`Fourth and Federal Circuits, the United States District Courts for the Eastern
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`District of Virginia, the Western District of Virginia, the District of Columbia, the
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`Eastern District of Texas, the Western District of Texas, the District of Colorado,
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`and all state courts in Virginia and the District of Columbia. I have also been
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`admitted to practice and have appeared pro hac vice before, among others, the
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`United States District Courts for the District of Massachusetts, the Southern and
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`Western Districts of New York, the Central District of California, the Southern
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`District of California, the District of Maryland, the Western District of Washington,
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`and the District of Delaware.
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`2
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`Ex. 2017 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
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`4.
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`I have also appeared before the United States International Trade
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`Commission and have practiced and continue to practice regarding trademark
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`matters before the United States Patent and Trademark Office, and the Trademark
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`Trial and Appeal Board.
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`5.
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`I am a member of the American Intellectual Property Law
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`Association.
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`6.
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`I have extensive experience in litigating patent infringement
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`matters. I have been litigating patent infringement cases since my admission to
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`the bar in 1997. I have served as lead counsel in such cases, including cases in
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`the Eastern District of Texas, the Western District of Texas, the Central District
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`of California, the Western District of Washington, the District of Colorado, and
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`the District of Delaware, and have appeared before the Court of Appeals for the
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`Federal Circuit numerous times regarding appeals in patent infringement cases.
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`7.
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`I have never been suspended, disbarred, sanctioned, or cited for
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`contempt by any court or administrative body.
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`8.
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`I have never had a court or administrative body deny my
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`application for admission to practice.
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`9.
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`I have read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials, as set forth in Part 42 of the
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`C.F.R.
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`3
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`Ex. 2017 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
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`10.
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`I agree to be subject to the United States 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 disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`11.
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`I have previously been granted admission pro hac vice to practice
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`before the Board in the matters of ZTE (USA), Inc. v. CyWee Group Ltd.,
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`IPR2019-00143, Google LLC v. CyWee Group Ltd., IPR2018-01257, Google
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`LLC v. CyWee Group Ltd., IPR2018-01258, Unified Patents Inc., v. Vilox
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`Technologies LLC, IPR2018-00044, and Salesforce.com, Inc. v. VirtualAgility
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`Inc., CBM2013-00024; and Intel Corporation v. FG SRC LLC, IPR2020-
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`01449. I have argued before the Board on several occasions and participated in
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`the trials of these matters before the Board.
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`12.
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`I have read and am familiar with the patent at issue in this
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`proceeding and its file history, as well as the prior art and other arguments that
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`have been asserted by petitioner.
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`13.
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`I declare, under penalty of perjury pursuant to 28 U.S.C. § 1746,
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`that all statements made herein of my knowledge are true and that all statements
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`made on information and belief are believed to be true.
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`Ex. 2017 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
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`Dated: April 28, 2022
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`Respectfully submitted,
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`/s/ Cecil E. Key
`Cecil E. Key
`DiMuroGinsberg PC - DGKEYIP GROUP
`1750 Tysons Blvd., Suite 1500
`Vienna, Virginia 22102
`Telephone: (703) 289-5118
`Fax: (703) 388-0648
`Email: ckey@dimuro.com
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`5
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`Ex. 2017 - IPR2021-00375
`Qualcomm Incorporated v. UNM Rainforest Innovations
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