UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`EPIC GAMES, INC.,
`Petitioner,
`
`v.
`
`INGENIOSHARE, LLC,
`Patent Owner
`
`U.S. PATENT NO. 10,142,810
`U.S. PATENT NO. 10,708,727
`U.S. PATENT NO. 10,492,038
`
`Case IPR2022-00202
`Case IPR2022-00291
`Case IPR2022-00294
`Case IPR2022-00295
`
`DECLARATION OF LINDSEY Y. SHI IN SUPPORT OF
`MOTION TO APPEAR PRO HAC VICE ON BEHALF OF
`PETITIONER EPIC GAMES, INC.
`
`Epic Games Ex. 1044
`Epic Games v. IngenioShare
`IPR2022-00294 p. 1
`
`
`____________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________________________
`
`EPIC GAMES, INC.,
`Petitioner,
`
`v.
`
`INGENIOSHARE, LLC,
`Patent Owner
`
`U.S. PATENT NO. 10,142,810
`U.S. PATENT NO. 10,708,727
`U.S. PATENT NO. 10,492,038
`
`Case IPR2022-00202
`Case IPR2022-00291
`Case IPR2022-00294
`Case IPR2022-00295
`
`DECLARATION OF LINDSEY Y. SHI IN SUPPORT OF
`MOTION TO APPEAR PRO HAC VICE ON BEHALF OF
`PETITIONER EPIC GAMES, INC.
`
`Epic Games Ex. 1044
`Epic Games v. IngenioShare
`IPR2022-00294 p. 1
`
`
`
`I, Lindsey Y. Shi, do hereby declare:
`
`IPR2022-00202
`IPR2022-00291
`IPR2022-00294
`IPR2022-00295
`
`
`1.
`
`I am a partner in the law firm Kirkland & Ellis LLP (“Kirkland”).
`
`Lead counsel in these inter partes review proceedings is W. Todd Baker, who is also
`
`a Kirkland partner, is registered to practice before the PTO, and holds Registration
`
`No. 45,265. With respect to these proceedings, I work closely with Mr. Baker.
`
`2.
`
`I hold a Bachelor of Science degree in Chemical Engineering from the
`
`Massachusetts Institute of Technology. I hold a Juris Doctor degree from the
`
`University of California, Los Angeles School of Law.
`
`3.
`
`I have more than seven years of experience as a litigation attorney
`
`specializing in patent litigation. I represent clients in patent litigation matters in
`
`various United States District Courts. My experience includes, in relevant part, many
`
`matters related to computer systems, computer architectures, computer-based
`
`communications, and networked computer technologies. I am, therefore, an
`
`experienced patent litigation attorney with particular experience relevant to the
`
`technological and legal matters at issue in these proceedings. Petitioner Epic Games,
`
`Inc. desires and has a need to be represented in these these proceedings by an
`
`experienced patent litigation attorney who has particular expertise relevant to the
`
`issues in these proceedings.
`
`4.
`
`I am very familiar with U.S. Patent Nos. 10,142,810, 10,708,727, and
`2
`
`
`
`Epic Games Ex. 1044
`Epic Games v. IngenioShare
`IPR2022-00294 p. 2
`
`
`
`IPR2022-00202
`IPR2022-00291
`IPR2022-00294
`IPR2022-00295
`
`10,492,038 and with the legal subject matter, technical subject matter, and prior art
`
`discussed in Petitioner’s requests for inter partes review of these patents, which form
`
`the basis for these proceedings. I was counsel for Petitioner in the previous district
`
`court action related to these patents (IngenioShare, LLC v. Epic Games, Inc., Civil
`
`Action No. 21-cv-00663-ADA (W.D. Tex.), filed June 25, 2021) and was involved
`
`with factual and technical developments in that matter.
`
`5.
`
`In the present proceedings, I took the deposition of Patent Owner’s
`
`expert witness, Dr. George Rouskas, on October 27–28, 2022. Unintentionally, I
`
`had not yet moved to appear pro hac vice on behalf of Petitioner at the time of the
`
`deposition. However, lead counsel for Petitioner, W. Todd Baker (Reg. No. 45,265)
`
`served as second chair at the deposition of Dr. Rouskas and was present throughout
`
`the entire deposition. Counsel for Patent Owner made no objection to my
`
`participation in the deposition and does not oppose my motion to appear pro hac
`
`vice.
`
`6.
`
`After discovering my omission, I promptly prepared my declaration and
`
`concurrent motion to appear pro hac vice.
`
`7.
`
`I am a member in good standing of the Bar of the State of California. I
`
`am admitted to practice before the United States District Court for the Northern
`
`District of California and United States Court of Appeals for Veterans Claims.
`3
`
`
`
`Epic Games Ex. 1044
`Epic Games v. IngenioShare
`IPR2022-00294 p. 3
`
`
`
`IPR2022-00202
`IPR2022-00291
`IPR2022-00294
`IPR2022-00295
`
`I have never been suspended or disbarred from practice before any court
`
`8.
`
`or administrative body.
`
`9.
`
`I have never had a court or administrative body deny my application for
`
`admission to practice.
`
`10.
`
`I have never been sanctioned or cited for contempt by any court or
`
`administrative body.
`
`11.
`
`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 37 C.F.R.
`
`12.
`
`I agree to be subject to the United States Patent and Trademark Office
`
`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).
`
`13.
`
`I have participated in preparing multiple inter partes review petitions.
`
`In the past three years, I was admitted pro hac vice as counsel before the PTAB in
`
`Intel Corp. v. PACT XPP SCHWEIZ AG, IPR2020-00518.
`
`14.
`
`I 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 were made with the knowledge that willful, false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`4
`
`
`
`Epic Games Ex. 1044
`Epic Games v. IngenioShare
`IPR2022-00294 p. 4
`
`
`
`IPR2022-00202
`IPR2022-00291
`IPR2022-00294
`IPR2022-00295
`
`
`
`
`
`
`
`
`Date: December 9, 2022
`
`
`
`
`
`Respectfully submitted,
`
`/s/ Lindsey Y. Shi
`Lindsey Y. Shi
`
`
`
`
`5
`
`
`
`Epic Games Ex. 1044
`Epic Games v. IngenioShare
`IPR2022-00294 p. 5
`
`
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