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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`META PLATFORMS, INC.,
` Petitioner
`
`v.
`
`THALES VISONIX, INC.
`Patent Owner
`
`Case IPR2022-01304
`Patent 6,922,632
`
`DECLARATION OF AKSHAY S. DEORAS IN SUPPORT OF
`UNOPPOSED MOTION TO APPEAR PRO HAC VICE ON BEHALF OF
`PETITIONER
`
`
`
`
`
`
`
`
`
`
`
`
`META 1032
` IPR2022-01304
` META V. THALES
`
`
`
`
`
`I, Akshay S. Deoras, do hereby declare:
`
`1.
`
`I am a partner in the law firm Kirkland & Ellis LLP. Lead counsel in this Inter
`
`Partes review proceeding is W. Todd Baker, who is also a partner with the law
`
`firm Kirkland & Ellis LLP and is registered to practice before the United States
`
`Patent and Trademark Office under Registration No. 45,265. With respect to this
`
`proceeding, I will work closely with Mr. Baker.
`
`2.
`
`I hold Bachelor of Science degree in Electrical Engineering from Columbia
`
`
`
`University. I hold a Juris Doctor degree from the Columbia University School
`
`of Law.
`
`3.
`
`I have more than 14 years of experience as a litigation attorney who
`
`specializes in patent litigation and represents clients in patent litigation
`
`matters in various United States District Courts, the Court of Appeals for the
`
`Federal Circuit, and before the International Trade Commission. My
`
`experience includes many matters in the electrical and computer science arts,
`
`and I have particular experience relevant to the technological and legal matters
`
`at issue in this proceeding. I am, therefore, an experienced patent litigation
`
`attorney with particular expertise that is pertinent to this proceeding. Meta
`
`Platforms, Inc. (“Meta”) desires, and has a need, to be represented in certain
`
`1
`
`
`
`META 1032
`IPR2022-01304
` META V. THALES
`
`
`
`
`
`
`
`
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`aspects of these proceedings by an experienced patent litigation attorney who
`
`has particular expertise that is relevant to the issues in this proceeding.
`
`
`
`5.
`
`I am very familiar with U.S. Patent No. 6,922,632 and with the legal
`
`subject matter, technical subject matter, and prior art discussed in
`
`Petitioner’s Request for Inter Partes Review of U.S. Patent No. 6,922,632
`
`which forms the basis for this proceeding. I am currently counsel to Meta
`
`in the co-pending litigation relating to the same patent (Gentex
`
`Corporation et al. v Meta Platforms, Inc. et al., Case No. 4:22-cv-03892-
`
`YGR (N.D. Cal.) and am involved with factual and technical
`
`developments in that matter.
`
`6.
`
`I am a member in good standing of the Bar of the State of California and the
`
`State of New York. He is admitted to practice before the U.S. District Court
`
`for the Northern District of California and the U.S. Court of Appeals for the
`
`Federal Circuit.
`
`7.
`
`I have never been suspended or disbarred from practice before any court or
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`administrative body.
`
`8.
`
`I have never had a court or administrative body deny my application for
`
`admission to practice.
`
`
`
`2
`
`
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`META 1032
`IPR2022-01304
` META V. THALES
`
`
`
`
`
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`I have never been sanctioned or cited for contempt by any court or
`
`9.
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`administrative body.
`
`10.
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`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.
`
`11.
`
`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).
`
`12.
`
`In the past 3 years, I was admitted pro hac vice as counsel for before the
`
`PTAB in the following actions:
`
` Inter Partes Review IPR2020-01579, IPR2020-01583, and IPR2020-01585 as
`counsel for Apcon, Inc.
`
` Inter Partes Review IPR2020-001517, IPR2020-001518, IPR2020-001612,
`IPR2020-001613, and IPR2021-00187 as counsel for Omnitracs, LLC
`
` Inter Partes Review IPR2021-00323, IPR2021-00324, and IPR2021-00325 as
`counsel for XRS Corporation
`
`13.
`
`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
`
`
`
`3
`
`
`
`META 1032
`IPR2022-01304
` META V. THALES
`
`
`
`
`
`both, under Section 1001 of Title 18 of the United States Code and that such
`
`willful false statements may jeopardize the validity of U.S. Patent No.
`
`
`
`6,922,632.
`
` Date: April 11, 2023
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Akshay S. Deoras/
`Akshay S. Deoras
`KIRKLAND & ELLIS LLP
`555 California Street
`San Francisco, CA 94104
`Telephone: 415-439-1400
`Facsimile: 415-439-1500
`akshay.deoras@kirkland.com
`
`
`4
`
`
`
`META 1032
`IPR2022-01304
` META V. THALES
`
`
`
`
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