`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`APPLE, INC.,
`Petitioner
`
`v.
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`
`
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`ALIVECOR, INC.,
`Patent Owner
`
`___________________
`
`Case IPR2021-00970
`Patent No. 9,572,499
`___________________
`
`
`DECLARATION OF SEAN PAK IN SUPPORT OF
`MOTION FOR ADMISSION PRO HAC VICE
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`
`
`
`
`
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`
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`
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`
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`I, Sean Pak, declare as follows:
`
`1.
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`I am an attorney at the law firm of Quinn Emanuel Urquhart & Sullivan,
`
`LLP, counsel for Patent Owner AliveCor, Inc. (“AliveCor”). I submit this
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`declaration in support of the Motion for Admission Pro Hac Vice of Sean Pak. I
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`have personal knowledge of the facts set forth in this declaration and, if called upon
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`as a witness, I could and would testify to such facts under oath.
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`2.
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`I have been in private practice in the field of litigation since 2002. For
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`the majority of that time, my practice has focused on the field of intellectual property
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`litigation and, in particular, patent litigation.
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`3.
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`I am a member in good standing of the State Bar of California. I am
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`also admitted to practice before the following Courts:
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`• United States Court of Appeals for the Federal Circuit
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`• United States District Court for the Central District of California;
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`• United States District Court for the Southern District of California;
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`4.
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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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`5.
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`I have never had a court or administrative body deny my application for
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`admission to practice.
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`6.
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`I have read and will comply with the Office Patent Trial Practice Guide
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`and the Board’s Rules of Practice for Trials, as set forth in Part 42 of 37 C.F.R.
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`
`
`
`2
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`
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`7.
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`I agree to be subject to the United States Patent and Trademark Office
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`Rules of Professional Conduct, as set forth in 37 C.F.R. §§ 11.101 et seq., and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`8.
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`I have not previously sought pro hac vice appearance in any inter partes
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`review action.
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`9.
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`I am familiar with the subject matter at issue in this proceeding. I have
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`reviewed U.S. Patent No. 9,572,499 (“the ’499 patent”) and the prior art references
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`that are asserted by Apple to invalidate that patent.
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`10.
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`I currently represent AliveCor in Case No. 6-20-cv-01112 in the United
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`States District Court for the Western District of Texas, in which AliveCor alleges
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`that Apple infringes the ’499 patent and Apple asserts in defense that the claims of
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`the ’499 patent are invalid. I also represent AliveCor in investigation 337-TA-1266
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`before the United State International Trade Commission.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed in San Francisco, California on February 21, 2022.
`
`/s/ Sean S. Pak
`
`Sean S. Pak
`seanpak@quinnemanuel.com
`QUINN EMANUEL URQUHART &
`SULLIVAN, LLP
`50 California Street, 22nd Floor
`San Francisco, California 94111
`Tel: (415) 875-6600
`Fax: (415) 875-6700
`
`3
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