`____________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`DONGHEE AMERICA, INC. and DONGHEE ALABAMA, LLC,
`Petitioners
`v.
`PLASTIC OMNIUM ADVANCED INNOVATION AND RESEARCH,
`Patent Owner.
`____________
`Case IPR2017-01647
`Patent 6,814,921
`
`DECLARATION OF NICHOLAS H. LAM
`
`
`
`1.
`
`I, Nicholas H. Lam, am competent to present this declaration, and
`
`have personal knowledge of the facts set forth herein.
`
`2. This declaration is given in support of Petitioners Donghee America,
`
`Inc. and Donghee Alabama, LLC’s Motion for Pro Hac Vice Admission of
`
`Nicholas H. Lam.
`
`3.
`
`I am an associate at the law firm of Orrick, Herrington & Sutcliffe. I
`
`am an experienced litigating attorney and have been litigating patent cases for
`
`approximately ten (10) years.
`
`4.
`
`I have an established familiarity with the subject matter at issue in
`
`this proceeding. I am counsel for Donghee America, Inc. and Donghee Alabama,
`
`LLC (together, “Donghee”) in a co-pending district court case involving Patents
`
`6,814,921 (“’921 Patent”); 6,866,812 (“’812 Patent”); 7,166,253 (“’253 Patent”);
`
`9,079,490 (“’490 Patent”); 9,339,326 (“’326 Patent”); and 9,399,327 (“’327
`
`Patent”). That case is captioned Plastic Omnium Advanced Innovation and
`
`Research v. Donghee America, Inc. and Donghee Alabama, LLC, C.A. No. 16-
`
`187-LPS-CJB (D. Del.). I have been actively involved in the technical aspects of
`
`the district court case, including the validity of the ’921, ’812, ’253, ’490, ’326,
`
`and ’327 Patents. I have an in-depth familiarity with each of the patents, their file
`
`histories, and the references asserted as prior art by Donghee in this IPR
`
`proceeding.
`
`1
`
`
`
`5.
`
`6.
`
`I am a member in good standing of the State Bar of New York.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`7. No court or administrative body has ever denied my application for
`
`admission to practice before it.
`
`8. No court or administrative body has ever imposed sanctions or
`
`contempt citations on me.
`
`9.
`
`I have read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials set forth in Part 42 of Section 37
`
`of the C.F.R.
`
`10. I understand that I will be subject to the United States Patent and
`
`Trademark Office Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101
`
`et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`11. I am concurrently applying to appear pro hac vice in IPR2017-
`
`01605 (’253 Patent), IPR2017-01633 (’812 Patent), IPR2017-01647 (’921 Patent),
`
`IPR2017-01654 (’490 Patent), IPR2017-01890 (’327 Patent), and IPR2017-01945
`
`(’326 Patent), each of which pertains to a patent asserted in the co-pending district
`
`court case. Other than the foregoing, I have not applied to appear pro hac vice in
`
`any other proceeding before the Office in the last three (3) years.
`
`2
`
`
`
`12. I hereby declare that all statements made herein of my own
`
`knowledge are true and that all statements made on information and belief are
`
`believed to be true; and further that these statements were made with the
`
`knowledge that willful false statements and the like so made are punishable by fine
`
`or imprisonment or both under 18 U.S.C. 1001.
`
`Dated: July 5, 2018
`
`/Nicholas H. Lam/
` Nicholas H. Lam
`
`
`
`3
`
`
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