`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`ONE WORLD TECHNOLOGIES, INC.,
`D/B/A TECHTRONIC INDUSTRIES POWER EQUIPMENT
`Petitioner,
`
`v.
`
`CHERVON (HK) LIMITED,
`Patent Owner.
`
`Case IPR2020-00885
`U.S. Patent No. 9,648,805
`
`DECLARATION OF MATTHEW J. LEVINSTEIN IN
`SUPPORT OF CHERVON (HK) LIMITED’S MOTION
`FOR PRO HAC VICE ADMISSION OF
`MATTHEW J. LEVINSTEIN UNDER 37 C.F.R. § 42.10(c)
`
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`
`
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`
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`I, Matthew J. Levinstein, declare as follows:
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`1.
`
`2.
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`3.
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` I am an attorney licensed to practice law in the state of Illinois.
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` I am a member of good standing of the Bar of the State of Illinois.
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` I am also admitted to practice before the United States District Court
`
`for the Northern District of Illinois and the United States Courts of
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`Appeals for the Third, Seventh, and Federal Circuits.
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`4.
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` I am a member in good standing in all jurisdictions where I have been
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`admitted to practice.
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`5.
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` I have never been suspended or disbarred from practice before any court
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`or administrative body.
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`6.
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` I have never had an application denied for admission to practice before
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`any court or administrative body.
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`7.
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` I have never had any sanctions or contempt citations imposed by any
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`court or administrative body.
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`8.
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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 the
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`C.F.R.
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`9.
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` I agree to be subject to the USPTO Rules of Professional Conduct
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`37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37
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`C.F.R. §11.19(a).
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`2
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`
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`10.
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` I am a Shareholder at the law firm of Greenberg Traurig, LLP
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`(“Greenberg”). I joined Greenberg as an Associate in March 2010.
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`11.
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` I am an experienced litigating attorney and have specific experience in
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`patent law and patent law litigation. I have represented clients in
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`numerous patent infringement actions across the country. I have
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`litigated matters through trial and appeal.
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`12.
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` I have sought pro hac vice admission in the following matters filed by
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`Universal Remote Control, Inc.: IPR Nos. 2014-01082, 01084, 01102,
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`01103, 01104, 01106, 01109, 01111, 01112, and 01146. I have also
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`sought pro hac vice admission in the following matters filed by Kranos
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`Corporation d/b/a Schutt Sports: IPR Nos. 2016-01650, 01649, 01646,
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`and 2017-01530. I have not applied to appear pro hac vice in any other
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`proceedings before the United States Patent and Trademark Office in
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`the last three (3) years. (Id.)
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`13.
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` I have an established familiarity with the subject matter at issue in this
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`proceeding. I regularly represent Chervon (HK) Limited in matters
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`relating to its patents. For example, I represent Chervon (HK) Limited
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`in Chervon (HK) Limited et al. v. One World Technologies, Inc. et al.,
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`Case No. 1:19-cv-01293 (D. Del.), which involves the same patent at
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`issue in this IPR. As a result of my representation of Chervon (HK)
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`3
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`Limited in that matter, I have acquired substantial understanding of the
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`underlying technological issues at stake in this matter.
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`I hereby declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true;
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`and further that these statements are made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code and that such willful false
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`statements may jeopardize the validity of the patents at issue.
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`
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`Dated: May 22, 2020
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`
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`
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`Respectfully submitted,
`
`/Matthew J. Levinstein/
`Matthew J. Levinstein
`GREENBERG TRAURIG,
`LLP
`77 West Wacker Drive, Suite 3100
`Chicago, Illinois 60601
`(312) 456-8400
`(312) 456-8435
`
`Counsel for Chervon (HK) Limited
`
`4
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`
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that on the below date, I caused the forgoing to
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`be served by electronic mail to the following:
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`Lead Counsel
`
`Edward H. Sikorski. (Reg. No. 39,478)
`DLA Piper LLP (US)
`401 B Street, Suite 1700
`San Diego, CA 92101-4297
`Tel.: (619) 699-2645
`Fax: (619) 764-6645
`Ed.Sikorski@us.dlapiper.com
`
`
`
`
`
`Back-Up Counsel
`
`James M. Heintz (Reg. No. 41,828)
`DLA Piper LLP (US)
`One Fountain Square, Suite 300
`Reston, VA 20190-5602
`Tel.: (703) 773-4148
`Fax: (703) 773-5008
`James.Heintz@us.dlapiper.com
`
`Tiffany Miller (Reg. No. 52,032)
`DLA Piper LLP (US)
`401 B Street, Suite 1700
`San Diego, CA 92101-4297
`Tel.: (619) 699-3445
`Fax: (619) 764-6445
`Tiffany.Miller@us.dlapiper.com
`
`Date: May 22, 2020
`
`/James J. Lukas, Jr./
`
`
`
`5
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`
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