`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`SAMSUNG ELECTRONICS CO., LTD, MICRON TECHNOLOGY, INC.,
`MICRON SEMICONDUCTOR PRODUCTS, INC., and
`MICRON TECHNOLOGY TEXAS LLC
`Petitioner,
`
`v.
`
`NETLIST, INC.,
`Patent Owner.
`___________________
`
`Case No. IPR2022-00996
`Patent No. 11,016,918
`___________________
`
`DECLARATION OF JASON G. SHEASBY IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
`
`1
`
`Netlist EX2060
`Samsung v Netlist
`IPR2022-00996
`
`
`
`IPR2022-00996
`Patent No. 11,016,918
`
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`I, Jason G. Sheasby, declare as follows:
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`
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`1.
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`I am more than twenty-one years of age, am competent to present this
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`affidavit, and have personal knowledge of the facts set forth herein.
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`2.
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`This affidavit is given in support of the Patent Owner Netlist, Inc.'s
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`3.
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`4.
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`("Netlist") Motion for Pro Hac Vice Admission.
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`I am a Partner at the law firm Irell & Manella LLP.
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`I have been a litigating attorney for more than twenty (20) years, and
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`have been litigating patent cases during that entire time period. I
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`regularly litigate patent cases in various district courts, including the
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`United States Court of Appeals for the Federal Circuit. I have
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`represented clients in all aspects of litigation, including discovery,
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`Markman hearings, jury trials, bench trials, and appeals.
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`5.
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`I am a member in good standing of the Bar of the State of California.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
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`6.
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`No court or administrative body has ever denied my application for
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`admission to practice before it.
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` 2
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`
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`Netlist EX2060
`Samsung v Netlist
`IPR2022-00996
`
`
`
`IPR2022-00996
`Patent No. 11,016,918
`
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`7.
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`No court or administrative body has ever imposed sanctions or
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`contempt citations on me.
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`
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`8.
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`I have read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42
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`of Title 37, Code of Federal Regulations.
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`9.
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`I understand that I will be subject to the USPTO Code of Professional
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`Responsibility set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a).
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`10.
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`I have also appeared and been granted pro hac vice admission before
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`the United States Patent and Trademark Office in IPR2012-00033,
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`IPR2013-00242, IPR2014-01567, IPR2015-00370, IPR2015-00371,
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`IPR2015-00372, IPR2015-00374, IPR2015-00375, IPR2015-00377,
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`IPR2015-00378, IPR2018-00111, IPR2018-00215, IPR2018-00425,
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`IPR2018-00472, IPR2018-00487, IPR2019-01081, IPR2019-01082,
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`IPR2019-01083, CBM2019-00002, CBM2019-00003, CBM2019-
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`00004, CBM2019-00005, IPR2019-01331, IPR2019-01332, IPR2019-
`
`01333, IPR2020-00090, IPR2020-00091, IPR2020-00092, IPR2020-
`
`00095, IPR2020-00096, IPR2020-00097, IPR2020-00882, IPR2020-
`
`00975, IPR2020-00976, IPR2020-01101, IPR2021-00067, IPR2021-
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`
`
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` 3
`
`
`
`Netlist EX2060
`Samsung v Netlist
`IPR2022-00996
`
`
`
`
`
`IPR2022-00996
`Patent No. 11,016,918
`
`
`00071, IPR2021-01070, IPR2021-01073, IPR2021-01077, IPR2021-
`
`01163, IPR2021-01248, IPR2021-00966, IPR2021-00967, IPR2022-
`
`00615, IPR2022-00639, IPR2022-00076 and IPR2022-00075. I have
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`also applied for pro hac vice admission in IPR2018-00465, but the
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`proceeding was denied before the motion was approved. I am also
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`concurrently applying for pro hac vice admission in IPR2023-00999.
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`11.
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`I have established familiarity with the subject matter at issue in this
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`proceeding, including issues related to the validity of the ’918 Patent.
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`I have acquired substantial understanding of the underlying legal and
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`technological issues at stake in this and related proceedings. In
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`particular. I was substantively involved in the preparation of the
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`POPR submitted in this case. USAA has also spent significant time
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`and resources with me and wishes to rely on me as counsel in this
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`proceeding as appropriate, including in additional capacities, such as
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`for oral argument, and thereby benefit from my specific knowledge
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`and extensive litigation experience.
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`I declare under penalty of perjury that the foregoing is true and correct. I
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`declare that all statements made herein of my knowledge are true, and all
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`statements made on information and belief are believed to be true, and these
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` 4
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`
`
`Netlist EX2060
`Samsung v Netlist
`IPR2022-00996
`
`
`
`IPR2022-00996
`Patent No. 11,016,918
`
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`statements were made with the knowledge that willful false statements and the like
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`so made are punishable by fine or imprisonment, or both, under Section 1001 of
`
`Title 18 of the United States Code.
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`
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`
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`Date: August 28, 2023
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`/Jason G. Sheasby/
`Jason G. Sheasby
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Ste. 900
`Los Angeles CA 90067
`T: 310 203-7096
`F: 310 282-5712
` jsheasby@irell.com
`
`
`
` 5
`
`
`
`Netlist EX2060
`Samsung v Netlist
`IPR2022-00996
`
`