`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`VMware, Inc.
`Petitioner,
`
`v.
`
`Intellectual Ventures I LLC,
`Patent Owner.
`
`Case No. IPR2020-00470
`U.S. Patent No. 7,949,752
`
`DECLARATION OF MICHAEL R. RUECKHEIM IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
`
`VMware - Exhibit 1028
`VMware v. IV I - IPR2020-00470
`Page 1 of 3
`
`
`
`Pursuant to 37 C.F.R. § 1.68, I, Michael R. Rueckheim, attest to the following:
`
`1. I am a member in good standing of the Bars of the State of Texas,
`
`California, New York and admitted to practice in the following Federal Courts:
`
`a. United States Court of Appeals for the Federal Circuit;
`
`b. United States Court of Appeals for the Fifth Circuit;
`
`c. United States District Court for the Western District of Texas;
`
`d. United States District Court for the Eastern District of Texas;
`
`e. United States District Court for the Northern District of Texas;
`
`f. United States District Court for the Southern District of Texas;
`
`g. United States District Court for the Northern District of California;
`
`h. United States District Court for the Southern District of New York;
`
`i. United States District Court for the Northern District of Illinois; and
`
`j. United States District Court for the Eastern District of Wisconsin.
`
`2. I have not been suspended or disbarred from practice before any court
`
`or administrative body.
`
`3. I have never had an application for admission to practice before any
`
`court or administrative body denied.
`
`4. I have never had sanctions or contempt citations imposed by any court
`
`or administrative body imposed against me.
`
`5. I have read and will comply with the Office Patent Trial Practice Guide
`
`
`
`1
`
`VMware - Exhibit 1028
`VMware v. IV I - IPR2020-00470
`Page 2 of 3
`
`
`
`and the Board’s Rules of Practice for Trials set forth in Part 42 of Title 37, Code of
`
`Federal Regulations.
`
`6. I will be subject to the USPTO Code of Professional Responsibility set
`
`forth in 37 C.F.R. §§ 11.101 et seq., and to disciplinary jurisdiction under 37 C.F.R.
`
`§ 11.19(a).
`
`7. In the last three years, I have not applied to appear pro hac vice before
`
`the Board.
`
`8. I am counsel for Petitioner in Intellectual Ventures I LLC et al. v.
`
`VMware, Inc., Case No. 1:19-cv-1075-ADA (W.D. Tex.), filed on July 31, 2019,
`
`where the ’752 patent is currently being asserted.
`
`9. I am a litigation attorney and have been involved in multiple patent
`
`infringement cases in federal courts across the country. I have twelve (12) years of
`
`patent litigation experience. I have obtained substantial familiarity with the
`
`involved patent, the prior art, and the various issues raised in this proceeding. I was
`
`involved in the preparation of the Petition, am familiar with the subject matter
`
`involved in this proceeding, and have reviewed the Petition and the cited materials.
`
`10. I have a Bachelor of Science from the University of Texas, received
`
`in 2000.
`
`I declare under penalty of perjury that the foregoing is true and correct.
`
`Dated: August 13, 2020
`
`
`
`/Michael R. Rueckheim/
`Michael R. Rueckheim
`
`2
`
`VMware - Exhibit 1028
`VMware v. IV I - IPR2020-00470
`Page 3 of 3
`
`