`
` BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` APPLE INC.,
` Petitioner,
`
` v.
`
` ZENTIAN LTD.,
` Patent Owner.
`
` Case IPR2023-00037
` Patent No. 10,971,140
` ____________________
`
` DECLARATION OF KAYVAN B. NOROOZI IN SUPPORT OF
` MOTION FOR ADMISSION PRO HAC VICE
`
`
`
` I, Kayvan B. Noroozi, declare the following:
`
` 1.
`
` I am an attorney at Noroozi PC. I have been practicing law since
`
` November 2010 and have been practicing in the field of patent litigation since
`
` November 2012. In that time, I have been counsel of record in numerous patent
`
` litigation matters involving a variety of technologies, including cellular
`
` telecommunications, graphical user interfaces, mobile location, computer
`
` manufacturing and assembly, computer search and indexing, semiconductor
`
` Systems-on-a-Chip, light emitting diode and luminaire designs, and Power over
`
` Ethernet.
`
` 2.
`
` I am a member in good standing of the State Bar of California, and am
`
` admitted to practice before the Eastern District of Texas and Northern District of
`
` California.
`
` 3.
`
` 4.
`
` My California State Bar Membership number is 271167.
`
` I have never been suspended, disbarred, sanctioned, or cited for
`
` contempt by any court or administrative body.
`
` 5.
`
` I have never had a court or administrative body deny my application
`
` for admission to practice.
`
` 6.
`
` In the past five years, I have also applied to appear pro hac vice before
`
` the Office in the following other proceedings:
`
` 1
`
`
`
` IPR2023-00037
` D ECLARATION OF K AYVAN B. N OROOZI
`
` Proceeding
` IPR2018-00325
` IPR2018-00326
` IPR2018-00612
` IPR2018-00613
` IPR2018-00614
` IPR2018-00656
` IPR2018-00701
` IPR2018-00703
` IPR2018-00706
` IPR2018-00725
` IPR2018-00726
` IPR2018-00762
` IPR2018-00763
` IPR2018-00764
` IPR2018-00883
` IPR2018-01016
` IPR2018-01017
` IPR2018-01018
` IPR2018-01187
` IPR2018-01189
`
` Status
` Granted
` Granted
` Granted
` Pending when IPR terminated
` Granted
` Granted
` Granted
` Pending when IPR terminated
` Granted
` Granted
` Pending
` Granted
` Pending
` Granted
` Granted
` Granted
` Granted
` Granted
` Granted
` Granted
`
` 2
`
`
`
` IPR2023-00037
` D ECLARATION OF K AYVAN B. N OROOZI
`
` IPR2018-01538
` IPR2018-01630
` IPR2019-01259
` IPR2019-01260
` IPR2019-01261
` IPR2021-00275
` IPR2021-00569
` IPR2021-00614
` IPR2021-00615
` IPR2021-00644
` IPR2021-00729
` IPR2021-00731
` IPR2021-00827
` IPR2022-00341
` IPR2022-00342
` IPR2022-00348
` IPR2022-00455
` IPR2022-00462
` IPR2022-00467
` IPR2022-00468
` IPR2022-00618
` IPR2022-00626
` IPR2022-00648
`
` Granted
` Granted
` Granted
` Granted
` Granted
` Granted
` Pending when IPR terminated
` Pending when IPR terminated
` Pending when IPR terminated
` Pending when IPR terminated
` Pending when IPR terminated
` Pending when IPR terminated
` Granted
` Granted
` Granted
` Granted
` Granted
` Granted
` Granted
` Granted
` Granted
` Granted
` Granted
`
` 3
`
`
`
` IPR2023-00037
` D ECLARATION OF K AYVAN B. N OROOZI
`
` IPR2022-00715
` IPR2022-01508
` IPR2023-00033
` IPR2023-00034
` IPR2023-00035
` IPR2023-00036
`
` Granted
` Pending
` Pending
` Pending
` Pending
` Pending
`
` 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 title 37 of
`
` the Code of Federal Regulations.
`
` 8.
`
` I understand that I will be subject to the USPTO 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).
`
` 9.
`
` I am familiar with the subject matter of this proceeding through my
`
` review of the challenged patent and the record in this proceeding, as well as
`
` meetings and discussions with Patent Owner and its counsel.
`
` 10.
`
` I declare that all statements made herein of my knowledge are true
`
` and that all statements made on information and belief are believed to be true, and
`
` that these statements were made with knowledge that willful false statements and
`
` 4
`
`
`
` IPR2023-00037
` D ECLARATION OF K AYVAN B. N OROOZI
` the like are made punishable by fine or imprisonment, or both, under Section 1001
`
` of Title 18 of the United States Code.
`
` Dated: April 5, 2023
`
` By: /Kayvan Noroozi/
` Kayvan Noroozi
`
` 5
`
`