`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`CHANEL, INC.,
`Petitioner,
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`v.
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`MOLO DESIGN LTD.,
`Patent Owner.
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`Case IPR2022-00545
`U.S. Patent No. 9,689,161
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`DECLARATION OF SHANNON L. BJORKLUND IN
`SUPPORT OF CHANEL, INC.’S MOTION FOR PRO
`HAC VICE ADMISSION OF
`SHANNON L. BJORKLUND UNDER 37 C.F.R. § 42.10(c)
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`I, Shannon L. Bjorklund, declare as follows:
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`1.
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`2.
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`3.
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`I am an attorney licensed to practice law in the state of Minnesota.
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`I am a member of good standing of the Bar of the state of Minnesota.
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`I am also admitted to practice before the United States Court of Appeals
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`for the Federal Circuit; the United States Court of Appeals for the Eighth Circuit; and
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`the United States District Court for the District of Minnesota.
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`4.
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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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`I have never been suspended or disbarred from practice before any court or
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`administrative body.
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`I have never had an application denied for admission to practice before any
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`court or administrative body.
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`7.
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`I have never had any sanctions or contempt citations imposed by any court
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`or administrative body.
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`8.
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`I have read and will comply with the Office Patent Trial Practice Guide and
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`the Board’s Rules of Practice for Trials set forth in part 42 of the C.F.R.
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`9.
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`I agree to be subject to the USPTO Rules of Professional Conduct 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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`10.
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`I am a Partner at the law firm of Dorsey & Whitney, LLP (“Dorsey”) and am
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`counsel of record for Petitioner, Chanel, Inc. (“Chanel”) in the related district court
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`litigation, Molo Design, Ltd. v. Chanel, Inc., Civil No. 21-CV-1578 (VEC) (S.D.N.Y.)
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`(“S.D.N.Y. Litigation”). I joined Dorsey as an Associate in January 2011, following a
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`clerkship with the Honorable James B. Loken on the Eighth Circuit Court of Appeals.
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`11.
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`I am a litigation attorney with specific experience in patent law and patent
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`law litigation. I have represented clients in numerous patent infringement actions across
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`the country.
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`12.
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`I have not applied to appear pro hac vice in any proceedings before the
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`United States Patent and Trademark Office in the last three (3) 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 familiarity with the subject matter at issue in this proceeding and in
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`the related S.D.N.Y. Litigation in which U.S. Patent Nos. 7,866,366, 8,561,666,
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`9,689,161 and 9,797,134 were asserted by the Patent Owner in February 2021. Since
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`that time, I have closely studied the asserted patents, participated in discovery related
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`to the same, and submitted claim construction briefing for the terms of the foregoing
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`patents, all of which are part of the same patent family. I have acquired substantial
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`understanding of the underlying issues at stake in this matter.
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`I hereby 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 are made with the knowledge that willful false statements
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`and the like so made are punishable by fine or imprisonment, or both, under Section
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`1001 of Title 18 of the United States Code and that such willful false statements may
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`jeopardize the validity of the patents at issue.
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`Dated: August 16, 2022
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`Respectfully submitted,
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` /Shannon L. Bjorklund/
`Shannon L. Bjorklund
`bjorklund.shannon@dorsey.com
`DORSEY & WHITNEY LLP
`50 South Sixth Street, Suite 1500
`Minneapolis, MN 55402
`(612) 340-2600
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`Counsel for Chanel, Inc.
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on the below date, I caused the forgoing to
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`be served by electronic mail to the following:
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`Jared Schuettenhelm
`Registration No. 59,539
`Bracewell LLP
`701 Fifth Avenue, Suite 6200
`Seattle, WA 98104-7018
`(206) 204-6200 (t)
`(800) 404-3970 (f)
`jared.schuettenhelm@bracewell.com
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`Michael Chibib
`Registration No. 40,950
`Bracewell LLP
`111 Congress Avenue, Suite 2300
`Austin, TX 78701
`(512) 472-7800 (t)
`(800) 404-3970 (f)
`Michael.chibib@bracewell.com
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`Patrick J. Connolly
`Registration No. 69,570
`Bracewell LLP
`701 Fifth Avenue, Suite 6200
`Seattle, WA 98104-7018
`(206) 204-6200 (t)
`(800) 404-3970 (f)
`Patrick.connolly@bracewell.com
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`David Shargel
`1251 Avenue of the Americas, 49th Floor
`New York, NY 10020
`(212) 508-6100
`david.shargel@bracewell.com
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`Conor Civins
`111 Congress Avenue, Suite 2300
`Austin, TX 78701
`(512) 472-7800
`conor.civins@bracewell.com
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`Date: August 16, 2022
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` /Gina Cornelio/
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