`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`FLYWHEEL SPORTS, INC.,
`Petitioner
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`v.
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`PELOTON INTERACTIVE, INC.,
`Patent Owner
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`Case: IPR2019-01411
`U.S. Patent No. 10,322,315
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`DECLARATION OF RYAN JOSEPH SHEEHAN IN SUPPORT
`OF UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION
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`Flywheel Ex. 1045
`Flywheel v. Peloton
`IPR2019-01411
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`1.
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`I, Ryan Joseph Sheehan, am more than twenty-one years of age, am
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`competent to present this declaration, and have personal knowledge of the facts set
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`forth herein.
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`2.
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`This declaration is given in support of the Motion by Petitioner
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`Flywheel Sports, Inc. (“Flywheel” or “Petitioner”) for Pro Hac Vice Admission of
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`Ryan Joseph Sheehan.
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`3.
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`I am an associate at the law firm of Patterson Belknap Webb & Tyler
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`LLP (“Patterson”).
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`4.
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`I am an experienced litigating attorney. I have significant experience
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`litigating patent infringement cases. I have been counsel at Markman and
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`dispositive motion hearings and with respect to patent-related hearings, motions,
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`and pleadings concerning, inter alia, patent validity and infringement issues.
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`5.
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`I have over ten years of experience litigating patents related to
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`computer software, hardware, and networking technologies.
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`6.
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`I am counsel for Petitioner Flywheel in co-pending district court
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`litigation brought by the Patent Owner, Peloton Interactive, Inc. v. Flywheel
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`Sports, Inc., No. 2:18-CV-00390-RWS-RSP, filed on September 12, 2018, in the
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`U.S. District Court for the Eastern District of Texas, which involves U.S. Patent
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`No. 10,322,315 (the “’315 patent”) currently at issue in this proceeding.
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`1
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`Flywheel Ex. 1045
`Flywheel v. Peloton
`IPR2019-01411
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`7.
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`I have been actively involved in the aforementioned district court
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`litigation, including Petitioner’s ongoing factual investigation and development of
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`its non-infringement and invalidity positions regarding the claims of the ’315
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`patent, and have consequently gained in-depth familiarity with the subject matter at
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`issue in this proceeding.
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`8.
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`I have stayed up-to-date regarding the documents filed and actions
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`taken to date in the present matter and have carefully reviewed Petitioner’s
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`petition.
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`9.
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`I am a member in good standing of the State Bars of New York and
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`Connecticut, as well as the following Federal Courts:
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`United States Court of Appeals for the Federal Circuit
`United States District Court for the Eastern District of Texas
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`I have never been suspended or disbarred from practice before any
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`10.
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`court or administrative body.
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`11.
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`I have never made an application for admission to practice before any
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`court or administrative body that has been denied.
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`12. No sanctions or contempt citations have been imposed against me
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`personally by any court or administrative body.
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`13.
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`I have read and will comply with the Office Patent Trial Practice
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`Guide, the Trial Practice Guide Update (July 2019), and the Board’s Rules of
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`2
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`Flywheel Ex. 1045
`Flywheel v. Peloton
`IPR2019-01411
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`Practice for Trials set forth in part 42 of Title 37 of the Code of Federal
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`Regulations.
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`14.
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`I understand that I will be subject to the USPTO Rules of Professional
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`Conduct as set forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction
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`under 37 C.F.R. § 11.19(a).
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`15.
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`I declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true,
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`and further that these statements were made with the knowledge that willful false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code.
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`Executed on October 1, 2019.
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` /s/ Ryan Joseph Sheehan
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`Ryan Joseph Sheehan
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`3
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`Flywheel Ex. 1045
`Flywheel v. Peloton
`IPR2019-01411
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