UNITED STATES PATENT AND TRADEMARK OFFICE
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`QUALTRICS, LLC
`Petitioner
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`v.
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`OPINIONLAB, INC.
`Patent Owner
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`_______________
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`Case IPR2014-00366
`U.S. Patent 8,041,805
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`_______________
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`
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`DECLARATION OF PHILIP X. WANG IN SUPPORT OF
`PETITIONER QUALTRICS, LLC’S MOTION FOR
`PRO HAC VICE ADMISSION UNDER 37 C.F.R. § 42.10(c)
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`FILED VIA PRPS
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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`QUALTRICS, LLC
`Petitioner
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`v.
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`OPINIONLAB, INC.
`Patent Owner
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`_______________
`
`Case IPR2014-00366
`U.S. Patent 8,041,805
`
`_______________
`
`
`
`
`DECLARATION OF PHILIP X. WANG IN SUPPORT OF
`PETITIONER QUALTRICS, LLC’S MOTION FOR
`PRO HAC VICE ADMISSION UNDER 37 C.F.R. § 42.10(c)
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`
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`FILED VIA PRPS
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`Case IPR2014-00366
`Patent 8,041,805
`
`
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`
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` Declaration of Philip X. Wang Supporting
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` Qualtrics, LLC’s Motion for Pro Hac Vice
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`I, Philp X. Wang, resident of Los Angeles, California, declare as follows:
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`1.
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`I am an attorney at the firm of Latham & Watkins LLP, counsel of
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`record for Petitioner Qualtrics, LLC (“Petitioner”). I have personal knowledge of
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`the facts set forth in this declaration and, if called as a witness, could and would
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`testify competently under oath thereto.
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`2.
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`I am a member in good standing of the State Bar of California (Bar
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`No. 262239) and am also admitted to practice before the U.S. District Courts for
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`the Central District of California and the Northern District of California, and the
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`U.S. Court of Appeals for the Ninth Circuit.
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`3.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body. No application of mine for admission to practice
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`before any court or administrative body has ever been denied. No court or
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`administrative body has imposed sanctions or contempt citations against me.
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`4.
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`I have read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of the C.F.R.
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`I acknowledge and agree 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 under
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`37 C.F.R. § 11.19(a).
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`5.
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`I have an undergraduate degree in Computer Science from Stanford
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`Case IPR2014-00366
`Patent 8,041,805
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` Declaration of Philip X. Wang Supporting
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` Qualtrics, LLC’s Motion for Pro Hac Vice
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`University and graduated from Columbia University School of Law in 2008. While
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`at Stanford, I served as a research assistant in the Computer Science Department,
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`where I developed tools to find bugs in the source code automatically.
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`6.
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`I have over six years of patent litigation experience. I am a member of
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`Latham & Watkins intellectual property group, with a focus on patent litigation. In
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`2014, I was named a “Rising Star” by Super Lawyers magazine in the area of
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`intellectual property litigation.
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`7.
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`I have been actively involved in the related district court litigation
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`between OpinionLab, Inc. (the “Patent Owner”) and Petitioner, OpinionLab, Inc. v.
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`Qualtrics Labs, Inc. et al., 1:13-cv-01574 (N.D. Ill.) since January 2014. I was
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`granted leave to appear pro hac vice in that matter on May 19, 2014.
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`8.
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`U.S. Patent No. 8,041,805 (the “‘805 Patent”), which is at issue in this
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`proceeding, is one of six patents asserted by the Patent Owner in the district court
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`litigation. I have been actively involved in all aspects of the litigation, including
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`Petitioner’s factual investigation and development of its invalidity and claim
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`construction positions regarding the claims of the ‘805 Patent at issue here.
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`9.
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`I have been actively involved in analyzing and assisting with the
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`Petition for Inter Partes Review submitted in this proceeding, as well as the
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`petitions submitted in four related proceedings that are currently pending before
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`3
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`Case IPR2014-00366
`Patent 8,041,805
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` Declaration of Philip X. Wang Supporting
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` Qualtrics, LLC’s Motion for Pro Hac Vice
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`the Patent Trial and Appeal Board:
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`• Case No. IPR2014-00406: Petition for Inter Partes Review of U.S.
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`Patent No. 7,085,820, which is a continuation-in-part of U.S. Patent
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`No. 6,421,724; the ‘805 Patent – the patent at issue in this proceeding
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`– is a continuation of U.S. Patent No. 7,085,820;
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`• Case No. IPR2014-00356: Petition for Inter Partes Review of U.S.
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`Patent No. 6,606,581, which is a continuation-in-part of U.S. Patent
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`No.6,421,724;
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`• Case No. IPR2014-00420: Petition for Inter Partes Review of U.S.
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`Patent No. 7,370,285;
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`• Case No. IPR2014-00421: Petition for Inter Partes Review of U.S.
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`Patent No. 8,024,668, which is a continuation of U.S. Patent No.
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`7,370,285.
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`10.
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`I am concurrently seeking pro hac vice admission to appear in each of
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`these related proceedings. I have not applied to appear pro hac vice in any other
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`proceeding before the USPTO.
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`4
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`Case IPR2014-00366
`Patent 8,041,805
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` Declaration of Philip X. Wang Supporting
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` Qualtrics, LLC’s Motion for Pro Hac Vice
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`Executed on November 11, 2014 in Los Angeles, California.
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`Philip X. Wang
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`5
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`Case IPR2014-00366
`Patent 8,041,805
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` Declaration of Philip X. Wang Supporting
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` Qualtrics, LLC’s Motion for Pro Hac Vice
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e) and the parties’ agreement to electronic
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`service on August 21, 2014, I certify that on this 11th day of November,
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`2014, a copy of:
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`DECLARATION OF PHILIP X. WANG IN SUPPORT OF
`PETITIONER QUALTRICS, LLC’S MOTION FOR
`PRO HAC VICE ADMISSION UNDER 37 C.F.R. § 42.10(c)
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`was served by electronic mail on Patent Owner’s lead and backup counsel, at the
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`following email addresses:
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`Christopher W. Kennerly
`Paul Hastings LLP
`1117 S. California Ave.
`Palo Alto, CA 94304
`chriskennerly@paulhastings.com
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`Timothy P. Cremen
`Paul Hastings LLP
`875 15th Street, N.W.
`Washington, DC 20005
`timothycremen@paulhastings.com
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`Naveen Modi
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`Paul Hastings LLP
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`875 15th Street, N.W.
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`Washington, DC 20005
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` naveenmodi@paulhastings.com
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`6
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`Case IPR2014-00366
`Patent 8,041,805
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` Declaration of Philip X. Wang Supporting
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` Qualtrics, LLC’s Motion for Pro Hac Vice
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`By: /s/ Robert Steinberg
`
`Robert Steinberg
`Reg. No. 33144
`Neil A. Rubin
`Reg. No. 67030
`Latham & Watkins LLP
`355 South Grand Avenue
`Los Angeles, CA 90071-1560
`213.485.1234
`213.891.8763 (Fax)
`Counsel for Petitioner
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`7
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