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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`META PLATFORMS, INC.,
` Petitioner
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`v.
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`THALES VISONIX, INC.
`Patent Owner
`
`Case IPR2022-01304
`Patent 6,922,632
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`DECLARATION OF AKSHAY S. DEORAS IN SUPPORT OF
`UNOPPOSED MOTION TO APPEAR PRO HAC VICE ON BEHALF OF
`PETITIONER
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`META 1032
` IPR2022-01304
` META V. THALES
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`I, Akshay S. Deoras, do hereby declare:
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`1.
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`I am a partner in the law firm Kirkland & Ellis LLP. Lead counsel in this Inter
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`Partes review proceeding is W. Todd Baker, who is also a partner with the law
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`firm Kirkland & Ellis LLP and is registered to practice before the United States
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`Patent and Trademark Office under Registration No. 45,265. With respect to this
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`proceeding, I will work closely with Mr. Baker.
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`2.
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`I hold Bachelor of Science degree in Electrical Engineering from Columbia
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`University. I hold a Juris Doctor degree from the Columbia University School
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`of Law.
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`3.
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`I have more than 14 years of experience as a litigation attorney who
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`specializes in patent litigation and represents clients in patent litigation
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`matters in various United States District Courts, the Court of Appeals for the
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`Federal Circuit, and before the International Trade Commission. My
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`experience includes many matters in the electrical and computer science arts,
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`and I have particular experience relevant to the technological and legal matters
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`at issue in this proceeding. I am, therefore, an experienced patent litigation
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`attorney with particular expertise that is pertinent to this proceeding. Meta
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`Platforms, Inc. (“Meta”) desires, and has a need, to be represented in certain
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`1
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`META 1032
`IPR2022-01304
` META V. THALES
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`aspects of these proceedings by an experienced patent litigation attorney who
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`has particular expertise that is relevant to the issues in this proceeding.
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`5.
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`I am very familiar with U.S. Patent No. 6,922,632 and with the legal
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`subject matter, technical subject matter, and prior art discussed in
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`Petitioner’s Request for Inter Partes Review of U.S. Patent No. 6,922,632
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`which forms the basis for this proceeding. I am currently counsel to Meta
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`in the co-pending litigation relating to the same patent (Gentex
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`Corporation et al. v Meta Platforms, Inc. et al., Case No. 4:22-cv-03892-
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`YGR (N.D. Cal.) and am involved with factual and technical
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`developments in that matter.
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`6.
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`I am a member in good standing of the Bar of the State of California and the
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`State of New York. He is admitted to practice before the U.S. District Court
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`for the Northern District of California and the U.S. Court of Appeals for the
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`Federal Circuit.
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`7.
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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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`8.
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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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`META 1032
`IPR2022-01304
` META V. THALES
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`I have never been sanctioned or cited for contempt by any court or
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`9.
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`administrative body.
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`10.
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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 37 C.F.R.
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`11.
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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.
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`and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`12.
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`In the past 3 years, I was admitted pro hac vice as counsel for before the
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`PTAB in the following actions:
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` Inter Partes Review IPR2020-01579, IPR2020-01583, and IPR2020-01585 as
`counsel for Apcon, Inc.
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` Inter Partes Review IPR2020-001517, IPR2020-001518, IPR2020-001612,
`IPR2020-001613, and IPR2021-00187 as counsel for Omnitracs, LLC
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` Inter Partes Review IPR2021-00323, IPR2021-00324, and IPR2021-00325 as
`counsel for XRS Corporation
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`13.
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`I declare that all statements made herein of my own knowledge are true and
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`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
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`META 1032
`IPR2022-01304
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`both, under Section 1001 of Title 18 of the United States Code and that such
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`willful false statements may jeopardize the validity of U.S. Patent No.
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`6,922,632.
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` Date: April 11, 2023
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`Respectfully submitted,
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`/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
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`META 1032
`IPR2022-01304
` META V. THALES
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