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`PI- NET 2013
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`PI- NET 2013
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`Filed on behalf of Pi-Net International, Inc.
`By: Bryan Boyle
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`Gerald P. Dodson
`CARR & FERRELL LLP
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`120 Constitution Drive
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`Menlo Park, CA 94025
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`Tel: (650) 812-3400
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`Fax: (650) 812-3444
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`Covered Business Method Review of U.S. Patent No. 8,037,158
`_____________________
`SAP America, Inc.
`Petitioner
`v.
`Pi-Net International, Inc.
`Patent Owner
`_____________________
`CASE CBM 2014-00018
`Patent 8,037,158
`_____________________
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`Declaration of Dr. Lakshmi Arunachalam in Support of
`Motion for Pro Hac Vice Admission
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`1
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`Declaration of Dr. Lakshmi Arunachalam in Support of
`Motion for Pro Hac Vice Admission
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`I, LAKSHMI ARUNACHALAM, hereby declare as follows on behalf of myself—as the
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`named inventor of U.S. patent number 8,037,158—and as Chief Executive Officer
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`of Pi-Net International, Inc.:
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`1.
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`I am the named inventor of U.S. patent number 8,037,158, which is
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`the patent at issue in the present inter partes review proceeding.
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`2.
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`I am the Chief Executive Officer for the assignee of U.S. patent
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`number 8,037,158—Pi-Net International, Inc.—and am authorized to
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`make the present declaration on its behalf.
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`3.
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`Attorneys from the law firm of Lewis Roca Rothgerber LLP are
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`currently named as lead and back up counsel of record for the present
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`inter partes review proceeding. See PAPER NOS. 41-42 (filed March
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`10, 2014).
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`4.
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`I wish to seek the admission of an additional attorney with the law
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`firm of Lewis Roca Rothgerber LLP as counsel in the present case—
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`Mr. Colby B. Springer.
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`2
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`5.
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`I understand that while Mr. Springer is an attorney licensed to practice
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`law by the State Bar of California that he is not admitted to practice
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`before the United States Patent and Trademark Office.
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`6.
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`Notwithstanding Mr. Springer’s lack of admission before the United
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`States Patent and Trademark Office, I wish to have Mr. Springer
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`admitted in the above captioned case pro hac vice.
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`7.
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`I am aware that Mr. Springer would be subject to the supervision of
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`lead counsel in this matter, Ms. Tam Thanh Pham, who is a registered
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`practitioner before the United States Patent and Trademark Office.
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`8.
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`I believe that due to the quasi-litigation nature of an inter partes
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`review proceeding—including but not limited to limited document
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`discovery, protective orders, motion practice, direct examination via
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`declaration, cross-examination via deposition, oral argument, and the
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`Federal Rules of Evidence— that the interests of the patent owner, Pi-
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`Net International, Inc., would best be represented by both registered
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`patent practitioners (including the aforementioned Ms. Pham and Ms.
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`May Eaton—current back-up counsel for this proceeding) and an
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`experienced litigation attorney such as Mr. Springer.
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`9.
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`I am aware of Mr. Springer’s experiential background in patent
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`litigation and intellectual property and believe him to be an
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`3
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`experienced litigating attorney that would help best represent the
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`interests of the assignee in the present inter partes review proceeding.
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`10.
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`I have worked with Mr. Springer in various facets, since late 2008 or
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`early 2009, concerning the technical subject matter of U.S. patent
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`number 8,037,158.
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`11.
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`In light of those many years of experience, I believe—as both the
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`inventor of the patent at issue as well as the CEO for the assignee of
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`that patent—that Mr. Springer is quite familiar with the subject matter
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`at issue in the present inter partes review proceeding and has
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`extensive experience with the patents in my patent portfolio that
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`derive priority from U.S. provisional application number 60/006,634.
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`I believe that there is no one better suited than Mr. Springer to
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`represent Pi-Net International, Inc. before the Patent Trial and Appeal
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`Board in the various inter partes review proceedings and covered
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`business method proceedings for various patents in the Pi-Net
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`International portfolio.
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`12. The patent owner will not request any delay in the present or any
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`other proceedings on the basis that Mr. Springer is just now being
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`admitted pro hac vice.
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`13. The ppatent ownner will nott request a
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`delay in thhe present
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`or any othher
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`proceeeding on tthe basis thhat Mr. Sprringer is addmitted prro hac vice
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`4. The ppatent ownner will nott seek that
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`any order
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`or decisionn be
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`reconnsidered orr overturneed on the b
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`asis that MMr. Springeer may be
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`admitted pro haac vice.
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`5. The ppatent ownner respectffully requeests that MMr. Springerr be granteed
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`recoggnition to ppractice beefore the Paatent Trial
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`and Appeaal Board inn
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`this mmatter pro hac vice.
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`the ury under talty of perjuunder penaI declare uC. § 1746, h 38 U.S.CIn accorrdance wit
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`laws of the Unitedd States of America that the forregoing staatements arre true and
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`correct.
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` I understaand that willful false statementts and the llike are punnishable byy
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`fine or iimprisonmment, or botth (18 U.S..C. § 1001)) and may
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`jeopardizee the validiity
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`of the patent at isssue herein. All statemments madde of my owwn knowleedge are truue
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`and all sstatementss made on iinformation and belieef are belieeved to be
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`true.
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`March 111, 2014
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`5
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`Resspectfully ssubmitted,
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`___________________________________
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`Lakkshmi Arunnachalam
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`CEOO for the PPatent Ownner
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`Inveentor of UU.S. Patent NNo. 8,037,,158
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