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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 VISIONIX, INC.
`Patent Owner
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`U.S. PATENT NO. 6,922,632
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`IPR2022-01305
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`_________________________________________________
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`DECLARATION OF MELISSA B. COLLINS IN SUPPORT OF
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10(c)
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`EXHIBIT 2006
`Meta Platforms, Inc. v. Thales Visionix, Inc.
`IPR2022-01305
`Page 1
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`
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`I, Melissa B. Collins, am more than twenty-one years of age, am
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`competent to present this declaration, have personal knowledge of the facts set
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`forth herein, and hereby declare as follows:
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`1.
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`This declaration is given in support of Real Party-in-Interest Gentex
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`Corporation’s Motion for Admission pro hac vice.
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`2.
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`I am a partner at Williams & Connolly LLP, 680 Maine Avenue SW,
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`Washington, DC 20024. I have more than ten years of litigation experience.
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`3.
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`I am a member in good standing of the bars of New York and the
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`District of Columbia.
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`4.
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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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`5.
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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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`6.
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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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`7.
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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 of 37 C.F.R.
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`EXHIBIT 2006
`Meta Platforms, Inc. v. Thales Visionix, Inc.
`IPR2022-01305
`Page 2
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`
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`8.
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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 will be subject to
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`9.
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`I have not been admitted to appear pro hac vice before the Board in
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`the last three years.
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`10.
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`I am familiar with the subject matter at issue in the present
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`proceeding. This familiarity comes from having:
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`(i)
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`Served as counsel for Gentex in the co-pending district court
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`litigation, Gentex Corp. et al. v. Meta Platforms, Inc. et al., No. 22-cv-
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`03892-YGR (N.D. Cal.) for over a year since being admitted pro hac vice
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`while the case was proceeding in W.D. Texas on February 11, 2022;
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`(ii)
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`Reviewed in detail the Petition, the exhibits filed by Petitioner
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`in this proceeding, Patent Owner’s Preliminary Response, and exhibits filed
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`by Patent Owner in this proceeding;
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`(iii) Reviewed in detail the challenged patent, U.S. Patent No.
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`6,922,632;
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`(iv) Engaged in extensive strategic and substantive discussions
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`regarding this proceeding with Patent Owner’s and Real Party-in-Interest
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`Gentex Corporation’s counsel—Meredith Martin Addy, Robert P. Hart,
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`EXHIBIT 2006
`Meta Platforms, Inc. v. Thales Visionix, Inc.
`IPR2022-01305
`Page 3
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`
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`Gregory B. Gulliver, Brandon C. Helms, D. Shayon Ghosh, and Arthur J.
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`Argall III;
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`11.
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`I have reviewed in detail relevant case law and other legal authority
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`related to the allegations made in the Petition.
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`*
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`*
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`*
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`I hereby declare that all statements made herein of my own
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`knowledge are true and that all statements made on information and belief are
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`believed to be true, and further that these statements were made with the
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`knowledge that willful false statements and the like are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18, United States Code and
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`may jeopardize the validity of any application or any patent issuing thereon.
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`Executed on: April 21, 2023
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`By:
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` /Melissa B. Collins/
` Melissa B. Collins
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`EXHIBIT 2006
`Meta Platforms, Inc. v. Thales Visionix, Inc.
`IPR2022-01305
`Page 4
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`