`Parrot, Inc. v. Drone
`Technologies, Inc.
`IPR2014-00730
`
`
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`1, James E. Hopenfeld, do hereby declare and state, that all statements made
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`herein of my own knowledge are true and correct and all statements made on
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`information and belief are believed to be true and correct; and fimher that the
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`statements were made with the knowledge that willful false statements and the like
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`so made are punishable by fine or imprisonment, or both, under the laws of the
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`United States of America.
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`Dated: February9,2015
`
`31», V}
`
`‘
`
`.
`
`
`
`1.
`
`I am a Partner at Osha Liang LLP and represent Petitioners Parrot S.A
`
`and Parrot, Inc. (collectively, “Parrot” or “Petitioner”).
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`I am also lead counsel in
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`IPR2014—00730 and IPR2014—00732.
`
`2.
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`Due to clerical errors in the assembly of certain exhibits in both
`
`proceedings, Petitioner is seeking authorization to file corrected exhibits.
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`3.
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`Exhibit 1010 to the Petition for Inter Partes Review of U.S. Patent
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`No. 7,584,071 is the declaration of Prof. Raffaello D’Andrea,
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`in which he sets
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`forth his opinions of unpatentability of the claims of the ‘O71 patent. On behalf of
`
`Osha Liang LLP I prepared and represented Prof. D’Andrea at his deposition in
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`this proceeding, which occurred on January 8, 2015.
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`4.
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`In the course of preparing for the deposition,
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`I
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`learned that Prof.
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`D’Andrea’s CV was inadvertently not included in the declaration in Exhibit 1010
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`when it was filed, even though the declaration clearly describes the CV and refers
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`to it as being attached as “Appendix B” to the declaration. Upon further
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`investigation, I learned this was an error that was made during the assembly of the
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`exhibit prior to filing in PRPS, as we had received Prof. D’Andrea’s CV for his
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`declaration prior to the time of filing the IPR petitions.
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`5.
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`The
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`above-described
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`recently—discovered
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`clerical
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`error was
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`unintentional, is being promptly corrected, and has not caused any prejudice or
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`harm to Patent Owner. Indeed, it was not until Patent Owner’s counsel sent a letter
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`
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`dated January 22, 2015, that it became apparent that Patent Owner intended to
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`challenge Prof. D’Andrea’s declaration in the related proceeding (IPR2014-00732)
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`on the basis of a clerical error. Although under no obligation to do so, Petitioner
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`immediately investigated the issue and, on January 26, served copies of corrected
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`versions of the exhibits on Patent Owner.
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