`____________________________________________
`
`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
`IPR2022-00295 p. 1
`
`
`
`I, Lindsey Y. Shi, do hereby declare:
`
`IPR2022-00202
`IPR2022-00291
`IPR2022-00294
`IPR2022-00295
`
`
`1.
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`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.
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`I hold a Bachelor of Science degree in Chemical Engineering from the
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`Massachusetts Institute of Technology. I hold a Juris Doctor degree from the
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`University of California, Los Angeles School of Law.
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`3.
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`I have more than seven years of experience as a litigation attorney
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`specializing in patent litigation. I represent clients in patent litigation matters in
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`various United States District Courts. My experience includes, in relevant part, many
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`matters related to computer systems, computer architectures, computer-based
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`communications, and networked computer technologies. I am, therefore, an
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`experienced patent litigation attorney with particular experience relevant to the
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`technological and legal matters at issue in these proceedings. Petitioner Epic Games,
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`Inc. desires and has a need to be represented in these these proceedings by an
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`experienced patent litigation attorney who has particular expertise relevant to the
`
`issues in these proceedings.
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`4.
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`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
`IPR2022-00295 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
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`discussed in Petitioner’s requests for inter partes review of these patents, which form
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`the basis for these proceedings. I was counsel for Petitioner in the previous district
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`court action related to these patents (IngenioShare, LLC v. Epic Games, Inc., Civil
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`Action No. 21-cv-00663-ADA (W.D. Tex.), filed June 25, 2021) and was involved
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`with factual and technical developments in that matter.
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`5.
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`In the present proceedings, I took the deposition of Patent Owner’s
`
`expert witness, Dr. George Rouskas, on October 27–28, 2022. Unintentionally, I
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`had not yet moved to appear pro hac vice on behalf of Petitioner at the time of the
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`deposition. However, lead counsel for Petitioner, W. Todd Baker (Reg. No. 45,265)
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`served as second chair at the deposition of Dr. Rouskas and was present throughout
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`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.
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`6.
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`After discovering my omission, I promptly prepared my declaration and
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`concurrent motion to appear pro hac vice.
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`7.
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`I am a member in good standing of the Bar of the State of California. I
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`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
`IPR2022-00295 p. 3
`
`
`
`IPR2022-00202
`IPR2022-00291
`IPR2022-00294
`IPR2022-00295
`
`I have never been suspended or disbarred from practice before any court
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`8.
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`or administrative body.
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`9.
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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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`10.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
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`11.
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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 set forth in part 42 of 37 C.F.R.
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`12.
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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 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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`13.
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`I have participated in preparing multiple inter partes review petitions.
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`In the past three years, I was admitted pro hac vice as counsel before the PTAB in
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`Intel Corp. v. PACT XPP SCHWEIZ AG, IPR2020-00518.
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`14.
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`I declare that all statements made herein of my own knowledge are true
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`and that all statements made on information and belief are believed to be true; and
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`further that these statements were 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.
`4
`
`
`
`Epic Games Ex. 1044
`Epic Games v. IngenioShare
`IPR2022-00295 p. 4
`
`
`
`IPR2022-00202
`IPR2022-00291
`IPR2022-00294
`IPR2022-00295
`
`
`
`
`
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`
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`Date: December 9, 2022
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`
`
`
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`Respectfully submitted,
`
`/s/ Lindsey Y. Shi
`Lindsey Y. Shi
`
`
`
`
`5
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`
`
`Epic Games Ex. 1044
`Epic Games v. IngenioShare
`IPR2022-00295 p. 5
`
`