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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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`APPLE INC.,
`Petitioner
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`v.
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`KOSS CORPORATION,
`Patent Owner
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`Case IPR2021-00600
`Patent No. 10,298,451
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`DECLARATION OF DOUG WINNARD IN SUPPORT OF PETITIONER’S
`MOTION FOR PRO HAC VICE ADMISSION
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`APPLE 1027
`Apple v. Koss
`IPR2021-00600
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`1
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`Case IPR2012-00600
`Attorney Docket: 50095-0020IP1
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`I, Doug Winnard, being duly sworn and upon oath, hereby declare the
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`following:
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`1.
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`I am a member in good standing of the State Bar of California and Illinois, as
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`well as the United States Courts of Appeals for the Federal Circuit.
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`2.
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`I have not been suspended or disbarred from practice before any court or
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`administrative body.
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`3.
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`I have never had an application for admission to practice before any court or
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`administrative body denied.
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`4.
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`No sanction or contempt citation has been imposed against me by any court or
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`administrative body.
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`5.
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`I have read and will comply with the Office Patent Trial Practice Guide and the
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`Board’s Rules of Practice for Trials set forth in part 42 of the Code of Federal
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`Regulations.
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`6.
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`I will be subject to the USPTO Rules of Professional Conduct set forth in 37
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`C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`7.
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`In the past three years, I have not applied for admission pro hac vice in any
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`proceeding before the U.S. Patent and Trademark Office.
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`8.
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`I am an experienced litigation attorney with more than 11 years of experience
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`representing clients in patent cases involving consumer electronics, computer
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`software, and semiconductors. I regularly litigate patent cases in various forums
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`Case IPR2012-00600
`Attorney Docket: 50095-0020IP1
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`including the Federal District Courts, and the International Trade Commission.
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`Through my experience in patent litigation matters, I have represented clients in many
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`phases of litigation including discovery, Markman hearings, trials, and appeals. My
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`biography is attached hereto as Exhibit A.
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`9.
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`I serve as trial counsel for Apple in a litigation that involves the same patent
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`that is at issue in the above-captioned inter partes review proceeding, styled Koss
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`Corporation v. Apple Inc., W.D. Tex. Case. No. 6:20-cv-00665. As a result, am
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`intimately familiar with the issues and subject matter presented in this above-
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`captioned inter partes review proceeding. For example, I have extensively reviewed
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`the above identified patent, its prosecution history, the Petition for IPR (including the
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`invalidity grounds therein, and the cited references) and all exhibits filed in this case.
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`10.
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`I declare that all statements made herein of my knowledge are true, and that
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`all statements made on information and belief are believed to be true, and that these
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`statements were made with the knowledge that willful false statements and the like
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`so made are punishable by fine or imprisonment, or both, under Section 1001 of
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`Title 18 of the United States Code.
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`Date: 1/28/2022
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`Case IPR2012-00600
`Attorney Docket: 50095-0020IP1
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`Respectfully submitted,
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`/Doug Winnard/
`Doug Winnard
`Goldman Ismail Tomaselli Brennan & Baum LLP
`200 South Wacker Dr., 22nd Floor
`Chicago, IL 60606
`P 312-881-5954
`dwinnard@goldmanismail.com
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`Case IPR2012-00600
`Attorney Docket: 50095-0020IP1
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`EXHIBIT A 
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`Doug Winnard
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`Partner/Chicago
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`P 312-881-5944
`F 312-380-7018
`dwinnard@goldmanismail.com
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`Doug has a wealth of litigation experience in intellectual
`property, commercial litigation, and products liability.
`Doug has served as lead counsel for major companies in
`several patent infringement matters. He has worked on all
`stages of complex litigation, from preliminary analysis to
`trial, and in many different fields, from pharmaceutical
`products to chromatography and aerial mapping. He has
`represented clients in three patent infringement trials: a
`jury trial, a federal bench trial, and a hearing at the
`International Trade Commission. He obtained favorable
`results each time.
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`Private Practice
`Partner, Goldman Ismail Tomaselli Brennan & Baum LLP
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`Associate, Goldman Ismail Tomaselli Brennan & Baum LLP
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`Associate, Irell & Manella LLP
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`Education
`Northwestern Pritzker School of Law (J.D., cum laude)
` Wigmore Scholar
` Order of the Coif
` Northwestern Law Review, Membership editor,
`Lowden-Wigmore Prize for Legal Scholarship
` Winner, Julius Miner Moot Court Competition
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` University of Virginia (B.A., Economics and
`Government, with distinction)
` Echols Scholar
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`Of Note
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`Selected for Benchmark Litigation’s 40 & Under Hot List (2021)
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`Selected by Super Lawyers as an Illinois Rising Star (2018-2022)
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`Representative Litigation
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`Consumer Electronics Litigation
` Represents Fortune 10 consumer electronics company in ten patent-
`infringement cases brought by Uniloc, a prolific non-practicing entity,
`relating to telecommunications, user-interface, computer security, and
`battery technologies. Successfully argued on appeal at the Federal Circuit,
`obtaining favorable judgment in a precedential opinion. Helped secure a
`dismissal with prejudice as to one patent. Secured dismissal of multiple
`Uniloc cases based on constitutional standing ground, derailing Uniloc’s
`nationwide litigation campaign against numerous defendants.
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` Represents Fortune 10 company in patent infringement action brought by
`Koss Corporation.
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` Represented Fortune 10 company as lead counsel in patent infringement
`action brought by non-practicing entity Mesa Digital, LLC. Obtained a
`stipulation of dismissal of all claims with prejudice.
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` Represented Fortune 10 consumer electronics company in patent-
`infringement case brought by SMTM Technology, LLC.
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`Hatch-Waxman Litigation
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` Represents Merck as co-counsel in Hatch-Waxman patent infringement
`action brought against sixteen groups of defendants related to Merck’s
`Bridion® medicine for reversal of neuromuscular block.
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` Represented Merck as co-counsel in Hatch-Waxman patent infringement
`action related to Merck’s Nasonex® nasal spray. Obtained favorable
`settlement.
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`In re Tampa Bay Rays Baseball Ltd. TCPA Litigation
`Represented Major League Baseball Advanced Media in putative class action
`related to claims arising under Telephone Consumer Protection Act. Obtained
`favorable settlement.
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`Cedar Lane Technologies v. Teledyne Digital Imaging US, Inc.
`Represented Teledyne Digital Imaging as lead counsel in patent infringement
`action. Obtained favorable settlement.
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`Uniloc v. Home Box Office, Inc.
`Represented HBO in patent infringement action. Obtained judgment of invalidity on
`motion to dismiss, which was subsequently affirmed on appeal.
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`Front Row Technologies LLC v. MLB Advanced Media, L.P.
`Represented Major League Baseball Advanced Media in patent infringement
`action. Obtained dismissal of all claims with prejudice.
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`Vioxx Litigation - Government Action Cases
`Represented Merck Sharp & Dohme Corp. in several actions brought by State
`Attorneys General.
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`Visual Intelligence LP v. Optech, Inc.
`Represented defendant aerial mapping system manufacturer in patent infringement
`action.
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`Alltech Associates, Inc. v. Teledyne Instruments
`Represented defendant scientific instrument manufacturer in patent infringement
`action. Obtained favorable settlement after close of discovery.
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`St. Jude Medical, Inc. v. AccessClosure, Inc. (prior to Goldman Ismail)
`Represented plaintiff medical device manufacturer in patent infringement action.
`Obtained jury verdict of $27.1 million, the largest jury verdict in the district to date.
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`Microsoft Corp. v. TiVo, Inc. (prior to Goldman Ismail)
`Represented respondent TiVo in Section 337 action for patent infringement.
`Following bench trial, Microsoft agreed to dismissal of all claims.
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