`_____________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`QUALCOMM INCORPORATED,
`
`Petitioner,
`
`v.
`
`UNM RAINFOREST INNOVATIONS,
`
`Patent Owner.
`_____________________
`Case IPR2021-00375
`
`Patent No. 8,265,096 B2
`_____________________
`
`
`
`
`
`
`DECLARATION OF CHRISTINE M. MORGAN IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10(c)
`
`Qualcomm Incorporated Ex. 1031
`Page 1 of 4
`
`
`
`IPR2021-00375
`Declaration of Christine M. Morgan
`
`I, Christine M. Morgan, declare the following:
`1.
`This declaration is given in support of Petitioner Qualcomm
`
`Incorporated’s (“Qualcomm” or “Petitioner”) Motion for Pro Hac Vice Admission
`
`of Christine M. Morgan.
`
`2.
`
`I am a partner with Reed Smith LLP and a member in good standing of
`
`the State Bar of California. I am admitted to practice before the United States District
`
`Court for the Northern of California, the United States District Court for the Central
`
`District of California, the United States District Court for the Eastern District of
`
`Texas, and the United States Court of Appeals for the Federal Circuit.
`
`3.
`
`I have never been suspended or disbarred from practice before any court
`
`or administrative body.
`
`4.
`
`No court or administrative body has imposed sanctions or contempt
`
`citations on me.
`
`5.
`
`No court or administrative body has denied an application for
`
`admission to practice filed by me.
`
`6.
`
`I have been practicing law since 1993 and have over 15 years of
`
`experience litigating patent infringement cases. I have litigated patent cases in many
`
`different district courts across the United States and before the International Trade
`
`Commission (“ITC”). My district court patent litigation experience includes arguing
`
`Markman hearings, dispositive motions, and many other patent-related hearings. In
`
`Qualcomm Incorporated Ex. 1031
`Page 2 of 4
`
`
`
`IPR2021-00375
`Declaration of Christine M. Morgan
`addition, l have participated in patent trials in several different venues, including the
`
`Northern District of California, the Eastern District of Texas, the Eastern District of
`
`Virginia, and the ITC. Among other responsibilities, my involvement in those trials
`
`included presenting lay and technical expert witness testimony. I also presented oral
`
`argument in the following two Covered Business Method Review trials: Miami
`
`International Holdings, Inc. et al v. Nasdaq, Inc. et al, CBM2018-00030, 00032.
`
`7.
`
`I also have appeared before the Court of Appeals for the Federal Circuit
`
`in connection with appeals of judgments entered in district court patent litigation,
`
`and was principal author of the appellate briefs in two such matters.
`
`8.
`
`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 of the Code
`
`of Federal Regulations.
`
`9.
`
`I understand that l will be subject to the USPTO Rules of Professional
`
`Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under
`
`37 C.F.R. § 11.19(a).
`
`10.
`
`I have an established familiarity with U.S. Patent No. 8,265,096 (“the
`
`’096 Patent”) and the subject matter of this inter partes review proceeding. I gained
`
`this familiarity through reviewing papers filed in this proceeding and through my
`
`role as counsel for Petitioner’s customers Dell Technologies Inc., Dell Inc., and
`
`EMC Corporation (collectively, “Dell”), in the co-pending district court proceeding
`
`Qualcomm Incorporated Ex. 1031
`Page 3 of 4
`
`
`
`IPR2021-00375
`Declaration of Christine M. Morgan
`captioned UNM Rainforest Innovations v. Dell Technologies Inc. et al., No. 6:20-
`
`cv-00468 (W.D. Tex.) (“the Dell litigation”), which also involves the ’096 Patent.
`
`11.
`
`I am in the process of seeking pro hac vice admission in IPR2021-
`
`00377 and IPR2021-00582 directed to two other patents asserted in the Dell
`
`litigation, and IPR2021-00734, IPR2021-00739, and IPR2021-00741 brought by
`
`Zyxel Communications Corporation. I have previously sought pro hac vice
`
`admission in CBM2018-00029, CBM2018-00030, and CBM2018-00032.
`
`12.
`
`I hereby 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 further that these statements are made with knowledge that willful false
`
`statements and the like are punishable by fine, imprisonment, or both, under Section
`
`1001 of Title 18 of the U.S. Code.
`
`Dated: September 27, 2021
`
`
`
`Respectfully submitted,
`/ Christine M. Morgan /
`Christine M. Morgan
`Reed Smith LLP
`101 Second Street
`Suite 1800
`San Francisco, CA 94105
`Tel: 415.543.8700
`Fax: 415.391.8269
`cmorgan@reedsmith.com
`Counsel for Petitioner
`
`Qualcomm Incorporated Ex. 1031
`Page 4 of 4
`
`