`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`META PLATFORMS, INC.,
`Petitioner
`
`Vv.
`
`THALES VISIONIX, INC.,
`Patent Owner
`
`U.S. PATENT NO.6,757,068
`U.S. PATENT NO.6,922,632
`U.S. PATENT NO. 7,725,253
`U.S. PATENT NO.7,301,648
`U.S. PATENT NO.8,224,024
`
`IPR2022-01294; IPR2022-01298; IPR2022-01301; IPR2022-01302;
`IPR2022-01303; IPR2022-01304; IPR2022-01305; IPR2022-01308
`
`DECLARATION OF GLEN PARKER
`
`IPR2022-01304
`IPR2022-01304
`Meta v. Thales
`Meta v. Thales
`Thales Exhibit 2020
`Thales Exhibit 2020
`Page 1 of 4
`Page 1 of 4
`
`
`
`I, Glen Parker, am more than twenty-one years of age, am competent
`
`to present this declaration, have personal knowledgeofthe facts set forth herein,
`
`and hereby declare as follows:
`
`1.
`
`[am Chief Operating Officer of Thales Defense & Security Inc.,
`
`which is the owner by merger of Thales Visionix, Inc. (“Thales”).
`
`2.
`
`I understand that on May 23, 2023, Dr. Ulrich Neumann, an expert
`
`witness for Petitioner Meta Platform’s Inc., was questioned at deposition by David
`
`M.Krinsky of the law firm Williams & Connolly LLP, counsel for Real-Party-in-
`
`Interest Gentex Corp. (“Gentex”). Attorneys who,at that time, were counsel of
`
`record for Thales attended the deposition remotely, with the expectation that
`
`Mr. Krinsky would conduct the questioning.
`
`I understand that Mr. Krinsky
`
`traveled from the Washington, DC area to San Francisco to take the deposition in
`
`person.
`
`3.
`
`I further understand that also on May 23, 2023, Petitioner’s counsel
`
`raised for the first time at the outset of that deposition an objection to Gentex’s
`
`counsel asking questions on behalf of Gentex and Thales.
`
`4.
`
`Thales consented to Mr. Krinsky’s questioning Dr. Neumann on
`
`behalf of both Thales and Gentex. No other attorney for Thales or Gentex asked
`
`(or came prepared to ask) any questions. Thales’s expectation wasthat
`
`Mr. Krinsky would be the sole questioner on Patent Owner’s side, which is whatin
`
`IPR2022-01304
`IPR2022-01304
`Meta v. Thales
`Meta v. Thales
`Thales Exhibit 2020
`Thales Exhibit 2020
`Page 2 of 4
`Page 2 of 4
`
`
`
`fact transpired after Petitioner’s counsel noted Petitioner’s objection but then stated
`
`that the deposition could proceed.
`
`5.
`
`I further understand that, after counsel for Petitioner raised its
`
`objection with the Patent Trial and Appeals Board on May 26, 2023, the Board
`
`informed the parties on May 31, 2023 that “only counsel for which Patent Owner
`
`has filed a powerof attorney (and subsequent mandatory notices) may ask
`
`questions of Petitioner’s expert in a deposition.”
`
`6.
`
`After learning of the Board’s May 31 decision, I promptly executed
`
`updated Powers of Attorney in IPR Proceeding Nos. IPR2022-01294, IPR2022-
`
`01298, IPR2022-01301, IPR2022-01302, IPR2022-01303, IPR2022-01304,
`
`IPR2022-01305, and IPR2022-01308 appointing David M. Krinsky, D. Shayon
`
`Ghosh, Arthur J. Argall III, Adam D. Harber, and Melissa Collins from Williams
`
`& Connolly LLPas attorneys authorized to transact business on behalf of Thales in
`
`the above-named proceedings. The updated Powers of Attorney were filed in each
`
`proceeding on May 31, 2023.
`
`7.
`
`Depositions in IPR Nos. IPR2022-01298, IPR2022-01301, IPR2022-
`
`01302, IPR2022-01303, IPR2022-01304, IPR2022-01305, and IPR2022-01308
`
`were subsequently conducted by Williams & Connolly LLP attorneys, just like the
`
`May 23 deposition by Mr. Krinsky, without objection by Petitioner.
`
`IPR2022-01304
`IPR2022-01304
`Meta v. Thales
`Meta v. Thales
`Thales Exhibit 2020
`Thales Exhibit 2020
`Page 3 of 4
`Page 3 of 4
`
`
`
`8.
`
`If Petitioner had timely raised its objection in advance of the May 23,
`
`2023 deposition of Dr. Neumann,allowing the Board to provide guidanceto the
`
`parties, I would have executed the updated Powers of Attorney appointing the
`
`above-named Williams & Connolly LLP attorneys as attorneys authorized to act on
`
`behalf of Thales at an earlier date, in advance of the May 23, 2023 deposition.
`
`I
`
`did not do so only because Meta did not makeits objection knownin time.
`
`9.
`
`Thales adopts the testimony taken in the May 23, 2023 deposition
`
`pursuant to questioning by Mr. Krinskyas if it were taken by Thales’s own
`
`attomeys.
`
`I hereby declare that all statements made herein of my own
`
`knowledgeare true and thatall statements made on information andbelief are
`
`believed to be true, and further that these statements were made with the
`
`knowledge that willful false statements and the like are punishable by fine or
`
`imprisonment, or both, under Section 1001 of Title 18, United States Code and
`
`may jeopardize the validity of any application or any patent issuing thereon.
`
`Executed on: ZA Nune
`
`, 2023
`
`By:
`
`Glen Parke
`
`IPR2022-01304
`IPR2022-01304
`Meta v. Thales
`Meta v. Thales
`Thales Exhibit 2020
`Thales Exhibit 2020
`Page 4 of 4
`Page4 of 4
`
`
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