`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`_________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`_________________
`
`
`TURNSIGNL, INC. AND TURNSIGNL FOUNDATION,
`Petitioners,
`
`v.
`
`REDMON JEANG LLC,
`Patent Owner.
`
`_________________
`
`CASE No. IPR2024-00104
`U.S. Patent No. 11,494,862
`_________________
`
`DECLARATION OF JUANITA DELOACH, PH.D.
`
`
`
`
`
`
`
`TurnSignl - Exhibit 1046
`Page 1 of 3
`
`
`
`I, Juanita DeLoach, make the following declaration based on my own personal
`
`knowledge and, if called to testify before the Board, could and would testify as
`
`follows:
`
`1.
`
`I hold a doctorate in electrical engineering from the University of Wisconsin-
`
`Milwaukee.
`
`2.
`
`I am an attorney at Barnes & Thornburg LLP, located at 2121 N. Pearl Street,
`
`Suite 700, Dallas, Texas 75201.
`
`3.
`
`4.
`
`I am a member in good standing of the Texas State Bar.
`
`I have never been subject to any suspensions or disbarments from practice
`
`before any court or administrative body.
`
`5.
`
`None of my applications for admission to practice before any court or
`
`administrative body has ever been denied.
`
`6.
`
`I have not been sanctioned nor had contempt citations imposed by any court
`
`or administrative body.
`
`7.
`
`I have read and will comply with Office Patent Trial Practice Guide and the
`
`Board's Rules for Practice for Trials, as set forth in 37 C.F.R. pt. 42.
`
`8.
`
`I will be subject to the United States Patent and Trademark Office Rules of
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`Professional Conduct as set forth in 37 C.F.R. §§ 11.101 et seq., and disciplinary
`
`jurisdiction under 37 C.F.R. § 11.19(a).
`
`2
`
`TurnSignl - Exhibit 1046
`Page 2 of 3
`
`
`
`9.
`
`This is my seventh application to appear pro hac vice in a proceeding before
`
`the Board. In the past three years, I have appeared via pro hac vice admission in the
`
`following cases:
`
`• IPR2023-00214 (Signify North America Corporation v. CAO Lighting, Inc.)
`
`• IPR2023-00213 (Signify North America Corporation v. CAO Lighting, Inc.)
`
`• IPR2021-00202 (Extrusion Group, LLC et al v. Kimberly-Clark Global Sales,
`
`LLC)
`
`10. As counsel for Petitioners TurnSignl, Inc. and TurnSignl Foundation, I have
`
`become very familiar with patents that cover technology that is similar to the
`
`technology at issue in this proceeding (e.g., mobile legal counsel systems and
`
`methods). Further, I spent time preparing and reviewing the filings for this
`
`proceeding.
`
`10.
`
`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 so made are punishable by fine or imprisonment, or both,
`
`under Section 1001 of Title 18 of the United States Code.
`
`
`
`Executed on November 28, 2023,
`
`_______________________________
`Juanita DeLoach, Ph.D.
`
`3
`
`TurnSignl - Exhibit 1046
`Page 3 of 3
`
`
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