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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`VOLKSWAGEN GROUP OF AMERICA, INC.,
`Petitioner,
`
`v.
`
`NEO WIRELESS,
`Patent Owner.
`
`Cases IPR2022-01537, IPR2022-01539, IPR2022-01567, IPR2023-00426
`Patents 10,075,941, 10,965,512, 10,447,450, 8,467,366
`
`FORD MOTOR COMPANY,
`Petitioner,
`
`v.
`
`NEO WIRELESS LLC
`Patent Owner.
`
`Cases IPR2023-00763, IPR2023-00764, IPR2023-00765, IPR2023-00766
`Patents 10,447,450, 10,965,512, 10,833,908, 10,075,941
`
`
`
`AMERICAN HONDA MOTOR CO., INC.,
`Petitioner,
`
`v.
`
`NEO WIRELESS LLC
`Patent Owner.
`
`Cases IPR2023-00790, IPR2023-00791, IPR2023-00793, IPR2023-00794,
`IPR2023-00797
`Patents 8,467,366, 10,075,941, 10,447,450, 10,833,908, 10,771,302
`
`GENERAL MOTORS LLC, NISSAN NORTH AMERICA, INC., TESLA, INC.,
`AND AMERICAN HONDA MOTOR CO., INC.,
`Petitioner,
`
`v.
`
`NEO WIRELESS LLC
`Patent Owner.
`
`Case IPR2023-00961
`Patent 10,965,512
`
`GENERAL MOTORS LLC AND NISSAN NORTH AMERICA, INC.,
`Petitioner,
`
`v.
`
`NEO WIRELESS LLC
`Patent Owner.
`
`Case IPR2023-00962
`Patent 10,447,450
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`GENERAL MOTORS LLC, NISSAN NORTH AMERICA, INC., AND TESLA
`INC.,
`Petitioner,
`
`v.
`
`NEO WIRELESS LLC
`Patent Owner.
`
`Cases IPR2023-00963, IPR2023-00964
`Patents 10,447,450, 10,075,941
`
`
`
`
`
`
`
`
`
`
`
`DECLARATION OF XU ZHOU
`IN SUPPORT OF PATENT OWNER’S
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION
`OF XU ZHOU UNDER 37 C.F.R. § 42.10(c)
`
`
`
`
`
`
`
`
`
`
`
`I, Xu Zhou, declare as follows:
`
`1.
`
`2.
`
`I am an attorney licensed to practice law in the State of Texas.
`
`I am a member in good standing in all jurisdictions where I have been
`
`admitted to practice.
`
`3.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`4.
`
`I have never had an application denied for admission to practice
`
`before any court or administrative body.
`
`5.
`
`I have never had any sanctions or contempt citations imposed upon
`
`me by any court or administrative body.
`
`6.
`
`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.
`
`7.
`
`I agree to be subject to the U.S.P.T.O. 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).
`
`8.
`
`9.
`
`I am an associate at the law firm of Caldwell Cassady Curry PC.
`
`I have practiced law in Texas since 2020, and the majority of my
`
`practice has consisted of patent related matters such as patent litigations.
`
`10. My experience in patent litigations includes drafting pleadings and
`
`motions, taking and defending depositions, attending hearings and trials, leading
`
`
`
`meet and confers, etc. Representative matters in which I am or was actively
`
`involved include:
`
`
`
`
`
`
`
`
`
`
`
`• VirnetX Inc. et al. v. Apple Inc., No. 6:12-cv-00855 (E.D.T.X.)
`
`• Match Group, LLC v. Bumble Trading Inc., No. 6:18-cv-00080
`
`(W.D.T.X.)
`
`• Huawei Technologies Co. Ltd. v. Verizon Communications Inc. et al.,
`
`No. 2:20-cv-00030 (E.D.T.X.)
`
`• Neo Wireless, LLC v. Dell Technologies Inc. et al., No. 6:21-cv-00024
`
`(W.D.T.X.)
`
`• In re Neo Wireless, LLC Patent Litigation, No. 2:22-md-03034
`
`(E.D.M.I.)
`
`• Nanoco Technologies Ltd. v. Samsung Electronics Co. et al., No.
`
`2:20-cv-00038 (E.D.T.X.)
`
`• BeSang Inc. v. Micron Technology, Inc. et al., No. 2:23-cv-00028
`
`(E.D.T.X.)
`
`• BeSang Inc. v. Intel Corporation, No. 3:23-cv-00113 (D. Or.)
`
`11.
`
`I have currently or previously appeared in the following matters:
`
`• Huawei Technologies Co. Ltd. v. Verizon Communications Inc. et al.,
`
`No. 2:20-cv-00030 (E.D.T.X.)
`
`
`
`• Neo Wireless, LLC v. Dell Technologies Inc. et al., No. 6:21-cv-00024
`
`(W.D.T.X.)
`
`• BeSang Inc. v. Micron Technology, Inc. et al., No. 2:23-cv-00028
`
`(E.D.T.X.)
`
`
`
`• BeSang Inc. v. Intel Corporation, No. 3:23-cv-00113 (D. Or.)
`
`12.
`
`I have not applied to appear pro hac vice in any other proceedings
`
`before the U.S.P.T.O. in the last three years.
`
`13.
`
`I have an established familiarity with the subject matter at issue in the
`
`following pending IPR proceedings involving my client Neo Wireless LLC and
`
`U.S. Patent No. 10,075,941. I have reviewed the 10,075,941 Patent, as well as the
`
`Petitions and the relevant art in the matters involving that Patent, IPR2022-01537,
`
`IPR2023-00766, IPR2023-00791, and IPR2023-00964. I am also representing Neo
`
`Wireless LLC in district court proceedings involving that Patent.
`
`14.
`
`I have an established familiarity with the subject matter at issue in the
`
`following pending IPR proceedings involving my client Neo Wireless LLC and
`
`U.S. Patent No. 10,965,512. I have reviewed the 10,965,512 Patent, as well as the
`
`Petitions and the relevant art in the matters involving that Patent, IPR2022-01539,
`
`IPR2023-00764, and IPR2023-00961. I am also representing Neo Wireless LLC in
`
`district court proceedings involving that Patent.
`
`
`
`15.
`
`I have an established familiarity with the subject matter at issue in the
`
`following pending IPR proceedings involving my client Neo Wireless LLC and
`
`U.S. Patent No. 10,447,450. I have reviewed the 10,447,450 Patent, as well as the
`
`Petitions and the relevant art in the matters involving that Patent, IPR2022-01567,
`
`IPR2023-00763, IPR2023-00793, IPR2023-00962, and IPR2023-00963. I am also
`
`representing Neo Wireless LLC in district court proceedings involving that Patent.
`
`16.
`
`I have an established familiarity with the subject matter at issue in the
`
`
`
`following pending IPR proceedings involving my client Neo Wireless LLC and
`
`U.S. Patent No. 8,467,366. I have reviewed the 8,467,366 Patent, as well as the
`
`Petitions and the relevant art in the matters involving that Patent, IPR2023-00426
`
`and IPR2023-00790. I am also representing Neo Wireless LLC in district court
`
`proceedings involving that Patent.
`
`17.
`
`I have an established familiarity with the subject matter at issue in the
`
`following pending IPR proceedings involving my client Neo Wireless LLC and
`
`U.S. Patent No. 10,833,908. I have reviewed the 10,833,908 Patent, as well as the
`
`Petitions and the relevant art in the matters involving that Patent, IPR2023-00765
`
`and IPR2023-00794. I am also representing Neo Wireless LLC in district court
`
`proceedings involving that Patent.
`
`18.
`
`I have an established familiarity with the subject matter at issue in the
`
`following pending IPR proceeding involving my client Neo Wireless LLC and
`
`
`
`U.S. Patent No. 10,771,302. I have reviewed the 10,771,302 Patent, as well as the
`
`Petition and the relevant art in the matter involving that Patent at issue and Neo
`
`Wireless LLC, IPR2023-00797. I am also representing Neo Wireless LLC in
`
`district court proceedings involving that Patent.
`
`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 are made with the knowledge that willful false
`
`statements and the like so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`
`
`
`
`
`
`
`Xu Zhou
`CALDWELL CASSADY CURRY PC
`
`Date: August 24, 2023
`
`
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