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UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`JUNIPER NETWORKS, INC.
`Petitioner
`
`v.
`
`IMPLICIT, LLC
`Patent Owner
`
`Case: IPR2020-00587
`Patent No. 9,591,104
`
`
`
`
`
`
`
`DECLARATION OF WILLIAM ELLSWORTH DAVIS, III
`IN SUPPORT OF MOTION FOR PRO HAC VICE ADMISSION
`
`I, William E. Davis, III, being duly sworn and upon oath, hereby attest to
`
`the following:
`
`1.
`
`2.
`
`I am a member in good standing of the Bar of Texas.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`3.
`
`I have never been denied an application for admission to practice
`
`before any court or administrative body.
`
`4.
`
`No sanction or contempt citation has ever been imposed against me
`
`by any court or administrative body.
`
`1
`
`
`
`
`
`
`
`

`

`5.
`
`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 37 C.F.R. Part 42.
`
`6.
`
`I will be subject to the USPTO 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).
`
`7.
`
`I am currently admitted pro hac vice before the Patent Trial and
`
`Appeal Board in Sonos, Inc. v. Implicit, LLC; IPR2018-00766 (Patent 7,391,791
`
`B2) and Sonos, Inc. v. Implicit, LLC IPR2018-00767 (Patent 8,942,252 B2).
`
`8.
`
`I am an experienced litigation attorney and have an established
`
`familiarity with the subject matter at issue in this proceeding. I have been practicing
`
`law since 2004 and have extensive experience litigating patent infringement cases
`
`in many different District Courts across the country. Among my experience in
`
`patent litigation matters, I have been lead counsel and counsel in multiple trials,
`
`Markman hearings, patent summary judgment proceedings, and other patent-
`
`related hearings and pleadings concerning, inter alia, patent validity and
`
`infringement issues.
`
`9.
`
`I am familiar with U.S. Patent Nos. U.S. Patent Nos. 8,694,683 (“the
`
`’683 Patent”); 9,270,790 (“the ’790 Patent”); 9,591,104 (“the ’104 Patent”);
`
`10,027,780 (“the ’780 Patent”); 10,033,839; (“the ’839 Patent”) and 10,225,378
`
`(“the ’378 Patent”). I have been representing Patent Owner Implicit in pending
`
`District Court litigation against Petitioner asserting the ’683, ’790, ’104, ’780, ’839
`
`
`
`2
`
`

`

`and ’378 Patents. Among other things, I have been involved in the infringement,
`
`claim construction, and validity issues with regard to the ’683, ’790, ’104, ’780,
`
`’839 and ’378 Patents.
`
` declare under penalty of perjury that the foregoing is true and correct. Executed
`
` I
`
`this 23rd day of July, 2020, in Longview, Texas.
`
`
`
`
`
`/s/ William E. Davis, III
`William E. Davis, III
`
`3
`
`

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