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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MERCEDES-BENZ USA, LLC,
`Petitioner
`v.
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`DAEDALUS PRIME LLC
`Patent Owner
`
`Case IPR2023-01333
`U.S. Patent No. 10,049,080
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`DECLARATION OF DAMON M. LEWIS
`IN SUPPORT OF PRO HAC VICE ADMISSION UNDER 37 C.F.R. § 42.10(c)
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Mercedes EX1036
`Mercedes v. Daedalus
`IPR2023-01333
`
`
`
`U.S. Patent No. 10,049,080
`Petition for Inter Partes Review
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`I, Damon Marcus Lewis, declare as follows:
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`1.
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`I am a Partner at the law firm of Hogan Lovells US LLP. I represent
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`and counsel Petitioner Mercedes-Benz USA, LLC (“Petitioner”), in connection with
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`the above-captioned inter partes review proceeding.
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`2.
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`I have been a member in good standing of the bars of Virginia, the
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`District of Columbia, U.S. Court of Appeals for the Federal Circuit, U.S. District
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`Court for the Eastern District of Virginia, and the U.S. District Court for the Eastern
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`District of Michigan.
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`3.
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`I have not been suspended or disbarred from practice before any court
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`or administrative body.
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`4.
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`I have never had an application for admission to practice before any
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`court or administrative body denied.
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`5.
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`I have never had a sanction or contempt citation imposed against me by
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`any court or administrative body.
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`6.
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`I have read and will comply with the Office Patent Trial Practice Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`7.
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`I understand that I will be subject to the USPTO Rules of Professional
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`Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction
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`pursuant to 37 C.F.R. § 11.19(a).
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`U.S. Patent No. 10,049,080
`Petition for Inter Partes Review
`I practice patent law, including patent litigation before courts and
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`8.
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`agencies, including U.S. District Courts, The International Trade Commission, and
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`the U.S. Court of Appeals for the Federal Circuit, and have done so throughout my
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`career as an attorney since 2006.
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`9.
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`As a part of my patent litigation experience, I have significant
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`knowledge and experience with litigating invalidity defenses, defending and
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`deposing witnesses, handling evidentiary issues, and arguing issues of claim
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`construction.
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`10.
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`I have worked on proceedings before the Board dating back to 2018.
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`This work experience includes: assisting with the preparation of petitions and other
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`submissions and preparing witnesses for deposition. I have not applied to appear pro
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`hac vice in any other proceedings before the Board in the last three (3) years.
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`11.
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`To date, I have worked with the named lead and back-up counsel to
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`develop and analyze the legal and factual issues raised in the Petition. I have been
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`significantly involved in the preparation of the Petition and supporting evidence,
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`particularly through my work in the parallel litigation involving this patent before
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`the United States International Trade Commission. Through this involvement, I have
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`gained in-depth familiarity with the arguments and evidence supporting the Petition,
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`including through the review and analysis of documents such as the challenged
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`3
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`U.S. Patent No. 10,049,080
`Petition for Inter Partes Review
`patent, the prosecution history of the challenged patent, technical literature, the
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`expert declaration, and other sources of information.
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`12.
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`I will work in coordination and association with the designated lead
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`counsel, Celine Jimenez Crowson, for the duration of my involvement in this
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`proceeding.
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`13.
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`I hereby declare that all statements made herein of my own knowledge
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`are true and that all statements made on information and belief are believed to be
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`true. I further declare that these statements were made with the knowledge that
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`willful false statements and the like so made are punishable by fine or imprisonment,
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`or both, under Section 1001 of Title 18 of the United States Code and that such
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`willful false statements may jeopardize the validity of this proceeding.
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`/s/ Damon M. Lewis
`Damon M. Lewis, Esq.
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`Date: April 29, 2024
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`HOGAN LOVELLS US LLP
`555 13th Street N.W.
`Washington, D.C. 20004
`Telephone: 202.637.5600
`Facsimile: 202.637.5710
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