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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PAYPAL, INC.,
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`Petitioner,
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`V.
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`MONEYCAT LTD.,
`Patent Owner
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`IPR2017-00541
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`U.S. Patent No. 8,712,918
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`Title: ELECTRONIC CURRENCY, ELECTRONIC WALLET THEREFOR
`AND ELECTRONIC PAYIVIENT SYSTEMS EMPLOYING THEM
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`DECLARATION OF JARED BOBROW IN SUPPORT OF PETITIONER’S
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`MOTION FOR ADMISSION PRO HAC VICE
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
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`P.O. Box 1450
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`Alexandria, VA 22313-1450
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`PayPal Ex.1025, p.1
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`1, Jared Bobrow, hereby declare as follows:
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`1.
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`I am a member in good standing of the State Bar of California.
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`I was
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`admitted to the California State Bar on June 16, 1988. My California Bar
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`membership number is 133712.
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`I am admitted to practice before the District
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`Courts of the Northern, Central, Southern and Eastern Districts of California, and
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`the Eastern District of Texas.
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`I am also admitted to practice before the California
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`State Supreme Court, U.S. Court of Appeals for the Federal Circuit, Ninth Circuit,
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`and First Circuit. Since 1988 I have practiced in the field of civil litigation. For
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`over 25 years, my practice has been focused on the field of intellectual property,
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`particularly patent litigation.
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`2.
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`I have never been suspended or disbarred from practice before any court or
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`administrative body.
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`3.
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`I have never had a court or administrative body deny my application for
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`admission to practice.
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`4.
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`I have never had any sanctions or contempt citations imposed on me by any
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`court or administrative body.
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`5.
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`I have read and will comply with the Office Patent Trial Practice Guide and
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`the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`PayPal Ex.1025, p.2
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`6.
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`I agree to be subject to the United States Patent and Trademark Office Rules
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`of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq., and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a).
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`7.
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`I have applied to appear pro hac vice before this office in the following
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`proceedings in the past three years: CBM20l4-00091, CBM2014-00092, and
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`CBM2014-00093.
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`I was admitted to practice in these proceedings, which are
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`related to the current proceeding, as back-up counsel on March 10, 2015, subject to
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`filing a supplemental declaration, which filing occurred on March 19, 2015. I have
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`also applied to appear pro hac vice before this office in the following proceeding in
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`the past three years:
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`IPR2015-00657, IPR20l5-00658, IPR2015—00660, IPR2015-
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`00662, and IPR2015-00666.
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`I was admitted to practice in these proceedings as
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`back-up counsel only on May 29, 2015.
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`I have also applied to appear pro hac vice
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`before this office in the following proceedings in the past three years: IPR2014-
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`01197, IRP2014—01207, and IPR20l4—01209. I was admitted to practice in these
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`proceedings as back-up counsel on September 16, 2015.
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`I have also applied to
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`appear pro hac vice before this office in the following proceedings in the past three
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`years:
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`IPR2016—00320, IPR2016-00322, IPR2016-00323, IPR2016-00330.
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`I was
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`admitted to practice in these proceedings as back-up counsel on September 26,
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`2016.
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`I have also applied to appear pro hac vice before this office in the following
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`proceeding in the past three years:
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`IPR2016—00782. The application was filed on
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`PayPal Ex.1025, p.3
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`October 3, 2016 and is pending before this office.
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`I have also applied to appear
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`pro hac vice before this office in the following proceedings: IPR2017-00279,
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`IPR2017-00280,
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`IPR2017-00281,
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`IPR2017-00282,
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`IPR2017-00391,
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`IPR20l7-
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`00392, and IPR2017—00406. These applications were filed on January 20, 2017
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`and are pending before this office.
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`I am also concurrently applying to appear pro
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`hac vice before this office in the following proceedings: CBM2017-00024,
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`CBM2017-00025,
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`CBM2017—00026,
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`CBM20l7-00027,
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`CBM2017—00028,
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`CBM2017—00029, as well as CBM2017—00030, and IPR2017-00542.
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`8.
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`I am an experienced litigation attorney, with particular experience in patent
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`infringement litigations in District Courts across the country, including experience
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`with fact and expert deposition discovery, claim construction, Markman hearings,
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`motion practice, trials, and hearings.
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`9.
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`I am counsel for PayPal, Inc. (“PayPal”), Petitioner and the defendant in a
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`related pending litigation in the United States District Court for the Northern
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`District of California,
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`in which U.S. Patent Nos. 7,590,602, 8,051,011, and
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`8,195,578 are asserted by the Patent Owner (MoneyCaz‘, Ltd. v. Pa)/Pal, Inc., Case
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`No. 14-cv-02490-JST (N.D. Cal.)). U.S. Patent No. 8,712,918 (the “918 patent”)
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`is a continuation of U.S. Patent No. 8,195,578 (the “578 patent”).
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`In
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`CBM2014—00093, a proceeding in which I was admitted pro hac vice as
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`backup counsel for the petitioner eBay Inc., the Board entered a final written
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`PayPal Ex.1025, p.4
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`decision that claims 1-3, 5-11, and 13-23 of the 578 patent are unpatentable.
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`Additionally, I was admitted pro hac vice as backup counsel for eBay in
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`CBM2014-00091
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`and CBM2014—00092,
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`concerning U.S. Patent Nos.
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`8,051,011 and 7,590,602, which are also related to the 918 patent.
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`I am
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`familiar with the subject matter at issue in this proceeding as a result of my
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`representation of PayPal in the related pending litigation, my representation of
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`eBay in CBM2014-00091, CBM2014-00092, and CBM2014-00093, and my
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`representation of eBay in MoneyCat’s appeal of the Board’s final written decisions
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`in those CBM proceedings to the Federal Circuit Court of Appeals (see Fed. Cir.
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`Nos. 2016-1399, 2016-1405, and 2016-1408).
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`I am familiar with the invalidity
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`defenses raised and prior art asserted in the related pending litigation and in the
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`related CBM proceedings, and am familiar with the prior art raised in this
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`proceeding, including: U.S. Patent No. 5,915,023 (“Bernstein”); Michael Peirce
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`and Donal O’Mahony, “Scalable, Secure Cash Payment for WWW Resources
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`With the PayMe Protocol Set,” World Wide Web Journal, Nov. 1995, at 587-601
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`(“Peirce”); WIPO Pub. No. WO 97/19414 (“Haynes”); and U.S. Patent No.
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`5,715,402 (“Popolo”).
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`I have reviewed the briefs and papers filed in this
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`proceeding
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`and
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`in
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`IPR2017-00542, CBM2014-00091, CBM2014—00092,
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`CBM20l4-00093, and CBM20 l 7-00030.
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`PayPal Ex.1025, p.5
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`I declare that all statements made herein of my own knowledge are true and
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`correct and that all statements made on information and belief are believed to be
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`true, and further that these statements were made with the knowledge that willful
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`false statements and the like so made are punishable by fine or imprisonment, or
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`both, under Section 1001 of Title 18 of the United States Code.
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`Respectfully submitted,
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`Dated: February 7, 2017
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`PayPal Ex.1025, p.6
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