`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 GEOFFREY M. GODFREY IN
`SUPPORT OF CHANEL, INC.’S MOTION FOR PRO
`HAC VICE ADMISSION OF
`GEOFFREY M. GODFREY UNDER 37 C.F.R. § 42.10(c)
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`I, Geoffrey M. Godfrey, declare as follows:
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`1.
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`I am an attorney licensed to practice law in the states of Washington,
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`California, and the District of Columbia.
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`2.
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`I am a member in good standing of the Bars of the states of Washington,
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`California, and the District of Columbia.
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`3.
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`I am also admitted to practice before the United States Courts of Appeals
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`for the Federal Circuit and D.C. Circuit; the United States District Courts for the
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`Eastern and Western Districts of Texas; the United States District Courts for the
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`Eastern and Western Districts of Washington; the United States District Court for the
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`District of Colorado; and the United States District Courts for the Central, Northern,
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`and Southern Districts of California.
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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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`5.
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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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`6.
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`I have never had an application denied for admission to practice before
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`any 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
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`court 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
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`and the Board’s Rules of Practice for Trials set forth in part 42 of the C.F.R.
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`2
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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
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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 a partner in April 2016.
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`11.
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`I have 20 years of experience in patent law and patent litigation and have
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`represented clients in numerous patent infringement actions across 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. (Id.)
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`13.
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`I have familiarity with the subject matter at issue in this proceeding and
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`in 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 acquired a substantial understanding of the underlying issues at stake
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`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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`3
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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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`
` /Geoffrey M. Godfrey/
`Geoffrey M. Godfrey
`godfrey.geoff@dorsey.com
`DORSEY & WHITNEY LLP
`Columbia Center
`701 Fifth Avenue, Suite 6100
`Seattle, WA 98104
`(206) 903-8800
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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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`5
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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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`6
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