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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`CLOUDFLARE, INC. AND SONICWALL INC.,
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`Petitioner,
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`v.
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`SABLE NETWORKS, INC.,
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`Patent Owner
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`____________
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`Case IPR2021-00909
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`Patent 8,243,593
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`____________
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`DECLARATION OF ERIN McCRACKEN
`IN SUPPORT OF PATENT OWNER’S
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION
`OF ERIN McCRACKEN
`UNDER 37 C.F.R. § 42.10(c)
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`Sable Networks, Inc. Exhibit 2005
`Page 2005 - 1
`IPR2021-00909, Cloudflare, Inc. v. Sable Networks, Inc.
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`I, Erin McCracken, declare as follows:
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`1.
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`2.
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`I am an attorney licensed to practice law in the State of California.
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`I am a member in good standing in all jurisdictions where I have been
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`admitted to practice.
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`3.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
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`4.
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`I have never had an application denied for admission to practice
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`before any court or administrative body.
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`5.
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`I have never had any sanctions or contempt citations imposed upon
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`me by any 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
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`7.
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`I agree to be subject to the U.S.P.T.O. Rules of Professional Conduct
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`set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37
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`C.F.R. § 11.19(a).
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`8.
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`9.
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`I am a partner at the law firm of Berger & Hipskind LLP.
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`I have practiced law in California since 2006, and part of my practice
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`has consisted of patent litigation and other patent related matters such as PTAB
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`litigations. A noncomprehensive list of representative patent litigations where I
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`have been actively involved as patent litigation counsel include:
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`Sable Networks, Inc. Exhibit 2005
`Page 2005 - 2
`IPR2021-00909, Cloudflare, Inc. v. Sable Networks, Inc.
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`• Sable Networks, Inc., et al. v. Cloudflare, Inc., No. 6:21-cv-00261-
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`ADA (W.D. Tex.).
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`• Sable Networks, Inc., et al. v. Splunk Inc., et al., No. 5:21-cv-00040-
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`RWS (E.D. Tex.).
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`• Castlemorton Wireless, LLC v. Ubiquiti Inc., No. 1:21-cv-00066-RGA
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`(D. Del.).
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`• SoftView LLC v. HTC Corp., No. 1:12-cv-00984 (D. Del.)
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`• SoftView LLC v. LG Electronics, No. 1:12-cv-00986 (D. Del.)
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`• SoftView LLC v. Apple Inc., No. 1:10-cv-00389 (D. Del.)
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`• Network Gateway Solutions LLC v. Adtran Inc., No. 1:09-cv-00667
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`(D. Del.)
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`• Konami Digital Entertainment Co., Ltd. v. Harmonix Music Systems,
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`Inc., 6:08-cv-00286 (E.D. Tex.)
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`• INOVA Diagnostics, Inc. v. Euro-Diagnostics AB, 3:08-cv-00845
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`(S.D. Cal.)
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`10. My experience in post-grant patent proceedings includes drafting
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`patent owner responses. Representative matters where I am or was actively
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`involved include:
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`• Cloudflare, Inc. v. Sable Networks, Inc., (IPR2021-00909).
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`• Cloudflare, Inc. v. Sable Networks, Inc., (IPR2021-00969).
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`Sable Networks, Inc. Exhibit 2005
`Page 2005 - 3
`IPR2021-00909, Cloudflare, Inc. v. Sable Networks, Inc.
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`• Cloudflare, Inc. v. Sable Networks, Inc., (IPR2021-01005).
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`• Cloudflare, Inc. v. Sable Networks, Inc., (IPR2021-01067).
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`•
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`•
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`•
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`•
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`Splunk Inc. v. Sable Networks, Inc., (IPR2021-01469).
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`Splunk Inc. v. Sable Networks, Inc., (IPR2021-01594).
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`Splunk Inc. v. Sable Networks, Inc., (IPR2022-00003).
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`Splunk Inc. v. Sable Networks, Inc., (IPR2022-00228).
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`11.
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`I am concurrently applying for pro hac vice admission in the
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`following matter before the U.S.P.T.O:
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`• Cloudflare, Inc. v. Sable Networks, Inc. (IPR2021-00969)
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`12. Other than the matter identified in ¶ 11 supra, I have not applied to
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`appear pro hac vice in any other proceedings before the U.S.P.T.O. in the last three
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`years.
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`13.
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`I have an established familiarity with the subject matter at issue in this
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`proceeding. I have reviewed the Patent at issue as well as the Petition and the
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`relevant art in this matter.
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`I hereby declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true.
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`and further that these statements are made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`Sable Networks, Inc. Exhibit 2005
`Page 2005 - 4
`IPR2021-00909, Cloudflare, Inc. v. Sable Networks, Inc.
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`Sable Networks, Inc. Exhibit 2005
`Page 2005 - 5
`IPR2021-00909, Cloudflare, Inc. v. Sable Networks, Inc.
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