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DECLARATION OF MR. YAKOV ZOLOTOREV IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
`
`I, Yakov “Jake” Zolotorev, hereby attest to the following:
`
`1.
`
`I am a member in good standing of the Bar of the State of California,
`
`as well as the following Federal Courts:
`
`a)
`
`2.
`
`United States District Courts for the Northern District of California.
`
`I have not been suspended or disbarred from practice before any court
`
`or administrative body.
`
`3.
`
`I have never had an application for admission to practice before any
`
`court or administrative body denied.
`
`4.
`
`No sanction or contempt citation has been imposed against me by any
`
`court or administrative body.
`
`5.
`
`I have read and will comply with the Patent Office Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
`
`6.
`
`I will be subject to the USPTO Code 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).
`
`7.
`
`In the last three (3) years, I have appeared pro hac vice before the
`
`Office in the following matters:
`
`Active\1606033266.2
`
`1
`
`PGR2023-00052 - Upstream Data
`Ex. 2001 - Page 1
`
`

`

`(a)
`
`IPR2020-00602 – NVIDIA Corporation v. Adeia Semiconductor
`
`Technologies LLC; and
`
`(b)
`
`IPR2020-00603 – NVIDIA Corporation v. Adeia Semiconductor
`
`Technologies LLC.
`
`(c)
`
`IPR2023-00039 – Crusoe Energy Systems, LLC v. Upstream Data Inc.
`
`8.
`
`I am a technically trained, experienced patent litigation attorney. I
`
`have experience in numerous patent infringement litigation matters in the federal
`
`court system. I have experience in Markman hearings, patent litigation trials and
`
`patent litigation appeals.
`
`9.
`
`I have represented Upstream Data Inc. since 2022 and am counsel for
`
`Upstream Data Inc. in the co-pending litigation in which U.S. Patent No.
`
`11,574,372 is asserted against Petitioner. I have an established familiarity with the
`
`subject matter at issue in this proceeding. In the co-pending litigation, I am a
`
`principal attorney responsible for the representation of Upstream Data Inc. While
`
`the co-pending litigation is at an early stage, I am involved in infringement case
`
`development, and expect to be involved in invalidity and claim construction
`
`analysis, all of which are related to the petition requesting post-grant review of
`
`U.S. Patent No. 11,574,372. I am also counsel for Upstream Data Inc. in the co-
`
`pending PGR2023-00039.
`
`Active\1606033266.2
`
`2
`
`PGR2023-00052 - Upstream Data
`Ex. 2001 - Page 2
`
`

`

`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
`
`December 11, 2023
`
` /Yakov Zolotorev/
`Yakov Zolotorev
`DLA Piper LLP (US)
`2000 University Avenue
`East Palo Alto, CA 94303
`Email: jake.zolotorev@us.dlapiper.com
`
`Active\1606033266.2
`
`3
`
`PGR2023-00052 - Upstream Data
`Ex. 2001 - Page 3
`
`

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