`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`META PLATFORMS, INC.
`Petitioner
`
`v.
`
`THALES VISIONIX, INC.
`Patent Owner
`
`U.S. PATENT NO. 6,922,632
`
`IPR2022-01305
`
`_________________________________________________
`
`DECLARATION OF MELISSA B. COLLINS IN SUPPORT OF
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10(c)
`
`EXHIBIT 2006
`Meta Platforms, Inc. v. Thales Visionix, Inc.
`IPR2022-01305
`Page 1
`
`
`
`I, Melissa B. Collins, am more than twenty-one years of age, am
`
`competent to present this declaration, have personal knowledge of the facts set
`
`forth herein, and hereby declare as follows:
`
`1.
`
`This declaration is given in support of Real Party-in-Interest Gentex
`
`Corporation’s Motion for Admission pro hac vice.
`
`2.
`
`I am a partner at Williams & Connolly LLP, 680 Maine Avenue SW,
`
`Washington, DC 20024. I have more than ten years of litigation experience.
`
`3.
`
`I am a member in good standing of the bars of New York and the
`
`District of Columbia.
`
`4.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`5.
`
`No court or administrative body has ever denied my application for
`
`admission to practice before it.
`
`6.
`
`No court or administrative body has ever imposed sanctions or
`
`contempt citations on me.
`
`7.
`
`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.
`
`EXHIBIT 2006
`Meta Platforms, Inc. v. Thales Visionix, Inc.
`IPR2022-01305
`Page 2
`
`
`
`8.
`
`I understand that I will be subject to the USPTO Code of Professional
`
`Responsibility set forth in 37 C.F.R. §§ 11.101 et seq. and will be subject to
`
`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`9.
`
`I have not been admitted to appear pro hac vice before the Board in
`
`the last three years.
`
`10.
`
`I am familiar with the subject matter at issue in the present
`
`proceeding. This familiarity comes from having:
`
`(i)
`
`Served as counsel for Gentex in the co-pending district court
`
`litigation, Gentex Corp. et al. v. Meta Platforms, Inc. et al., No. 22-cv-
`
`03892-YGR (N.D. Cal.) for over a year since being admitted pro hac vice
`
`while the case was proceeding in W.D. Texas on February 11, 2022;
`
`(ii)
`
`Reviewed in detail the Petition, the exhibits filed by Petitioner
`
`in this proceeding, Patent Owner’s Preliminary Response, and exhibits filed
`
`by Patent Owner in this proceeding;
`
`(iii) Reviewed in detail the challenged patent, U.S. Patent No.
`
`6,922,632;
`
`(iv) Engaged in extensive strategic and substantive discussions
`
`regarding this proceeding with Patent Owner’s and Real Party-in-Interest
`
`Gentex Corporation’s counsel—Meredith Martin Addy, Robert P. Hart,
`
`EXHIBIT 2006
`Meta Platforms, Inc. v. Thales Visionix, Inc.
`IPR2022-01305
`Page 3
`
`
`
`Gregory B. Gulliver, Brandon C. Helms, D. Shayon Ghosh, and Arthur J.
`
`Argall III;
`
`11.
`
`I have reviewed in detail relevant case law and other legal authority
`
`related to the allegations made in the Petition.
`
`*
`
`*
`
`*
`
`I hereby 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 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: April 21, 2023
`
`By:
`
` /Melissa B. Collins/
` Melissa B. Collins
`
`EXHIBIT 2006
`Meta Platforms, Inc. v. Thales Visionix, Inc.
`IPR2022-01305
`Page 4
`
`
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