`Filed on behalf of Amazon.com, Inc.
`By: Colin B. Heideman
`Joseph R. Re
`Nathan D. Reeves
`Logan P. Young
`KNOBBE, MARTENS, OLSON & BEAR, LLP
`925 4th Ave., Suite 2500
`Seattle, WA 98104
`Telephone: 206-405-2000
`Facsimile: 206-405-2001
`Email: BoxSEAZN2L1925LP6@knobbe.com
`
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________
`
`AMAZON.COM, INC.,
`Petitioner,
`
`v.
`
`JAWBONE INNOVATIONS, LLC,
`Patent Owner.
`
`
`
`Filed: July 6, 2023
`
`
`
`
`
`
`IPR2023-00251
`U.S. Patent No. 11,122,357
`
`
`
`
`
`
`
`
`
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`
`
`
`
`DECLARATION OF MARK LEZAMA IN SUPPORT OF
`UNOPPOSED PRO HAC VICE MOTION
`
`
`Amazon v. Jawbone
`U.S. Patent 11,122,357
`Amazon Ex. 1014
`
`
`
`Amazon.com, Inc. v. Jawbone Innovations, LLC
`IPR2023-00251
`
`
`I, Mark Lezama, declare and state as follows:
`
`1.
`
`I am a partner at Knobbe, Martens, Olson & Bear, LLP. Lead counsel
`
`for Petitioner Amazon.com, Inc., in this inter partes review proceeding is Colin B.
`
`Heideman, who is also a partner at my law firm. Mr. Heideman is registered to
`
`practice before the United States Patent and Trademark Office and holds Registra-
`
`tion No. 61,513. With respect to this proceeding, I will work closely with Mr.
`
`Heideman.
`
`2.
`
`I am admitted to practice before the United States Court of Appeals
`
`for the Federal Circuit. Over the past 16 years, I have represented clients in nu-
`
`merous litigations involving patents across the United States. Within the past five
`
`years alone, I have been counsel of record in or substantively involved in at least
`
`nine district-court litigations involving allegations of patent infringement or patent
`
`invalidity.
`
`3.
`
`I also have experience in inter partes review proceedings. The Board
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`previously admitted me pro hac vice in Amazon.com, Inc. and Amazon Web Ser-
`
`vices, LLC v. Personalized Media Communications, LLC, Case IPR2014-01528,
`
`and Guest Tek Interactive Entertainment Ltd. v. Nomadix, Inc., Cases IPR2019-
`
`00211 and IPR2019-00253.
`
`4.
`
`I am comfortable and experienced with technically and legally com-
`
`plex matters, such as will be present in this proceeding. For example, I am experi-
`
`-1-
`
`
`
`Amazon.com, Inc. v. Jawbone Innovations, LLC
`IPR2023-00251
`
`
`enced with technically and legally complex matters in the field of computer net-
`
`working and programming, and I have developed familiarity with the mathematics
`
`and technology of signal processing. In addition to my experience with technically
`
`and legally complex patent matters, I hold a bachelor’s degree in mathematics from
`
`Harvard College.
`
`5.
`
`I am familiar with U.S. Patent 11,122,357 and with the legal subject
`
`matter, technical subject matter, and cited art discussed in Petitioner’s request for
`
`inter partes review of U.S. Patent 11,122,357, which forms the basis for this pro-
`
`ceeding. I am counsel of record for Petitioner in the parallel district-court litiga-
`
`tion (case no. 22-cv-06727 (N.D. Cal.)) and have been involved in developing in-
`
`validity contentions for the ’357 patent in that case. In view of my legal experi-
`
`ence, technical background, and familiarity with the issues in the present matter,
`
`Petitioner has requested my services in the present matter. Denial of my appear-
`
`ance in this case would create an undue burden on Petitioner.
`
`6.
`
`I am a member in good standing of the Bar of the State of California.
`
`I am admitted to practice before the United States Court of Appeals for the Federal
`
`Circuit, the United States Court of Appeals for the Ninth Circuit, the United States
`
`District Court for the Central District of California, and the United States District
`
`Court for the Northern District of California.
`
`-2-
`
`
`
`Amazon.com, Inc. v. Jawbone Innovations, LLC
`IPR2023-00251
`
`
`7.
`
`I have never been suspended or disbarred from practice before any
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`court or administrative body.
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`8.
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`I have never had a court or administrative body deny my application
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`for admission to practice.
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`9.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
`
`10.
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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 Title 37 of
`
`the Code of Federal Regulations.
`
`11.
`
`I agree to be subject to the United States Patent and Trademark Office
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`Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq., and disci-
`
`plinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`12.
`
`I do not recall having appeared pro hac vice in proceedings before the
`
`United States Patent and Trademark Office in the last three years. I believe the last
`
`USPTO proceedings in which I formally appeared were Cases IPR2019-00211 and
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`IPR2019-00253, which terminated in May 2020.
`
`-3-
`
`
`
`Amazon.com, Inc. v. Jawbone Innovations, LLC
`IPR2023-00251
`
`
`I 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 fur-
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`ther that these statements were made with the knowledge that willful, false state-
`
`ments and the like so made are punishable by fine or imprisonment, or both, under
`
`Section 1001 of Title 18 of the United States Code.
`
`Executed on July 6, 2023.
`
`
`Mark Lezama
`
`
`
`
`
`
`
`57867410
`
`-4-
`
`
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