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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`DELL INC., ZTE (USA) INC.,
`and
`ZTE CORPORATION,
`Petitioners
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`v.
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`3G LICENSING S.A.,
`Patent Owner
`
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`IPR2020-01157
`U.S. Patent No. 7,274,933
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`AFFIDAVIT OF MR. NEIL BENCHELL IN SUPPORT OF
`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
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`3G EXHIBIT 2003
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`I, Neil Benchell, recognizing that willfully false misstatements subject me to
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`the penalty of perjury, hereby apply to appear pro hac vice before the Office in
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`Inter Partes Review proceedings for PTAB Case No. IPR2020-01157, and attest to
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`the following:
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`1.
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`I am an intellectual property litigation attorney at Devlin Law Firm
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`LLC (“Devlin Law Firm”). I joined Devlin Law Firm as an intellectual property
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`litigation attorney in 2018 and have been practicing in that capacity for 20 years at
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`several other law firms. While at previous firms and since joining Devlin Law
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`Firm, I have primarily focused my practice on patent litigation. In that time, I have
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`gained experience conducting technical infringement and validity analysis,
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`working with technical experts to prepare reports on infringement and validity
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`issues, preparing for depositions of technical experts and fact witnesses, briefing
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`claim construction issues, preparing for Markman hearings, and representing
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`clients in patent litigation trials and hearings before district courts around the
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`country.
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`2.
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`3.
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`I am a member in good standing of the Bar of Illinois.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body. No application of mine for admission to practice
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`before any court or administrated body has ever been denied. No court or
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`administrative body has imposed sanctions or contempt citations against me. I have
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`1
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`3G EXHIBIT 2003
`IPR2020-01157
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`never had an application for admission to practice before any court or
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`administrative body denied.
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`4.
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`I have read and will comply with the Office Patent Trial Practice Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of the C.F.R.
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`5.
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`I will be subject to the United States Patent and Trademark Office Code
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`of Professional Responsibility set forth in 37 C.F.R. § § 11.101 et seq. and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`6.
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`I am concurrently applying for pro hac vice admission in the
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`following proceedings: IPR2020-1158, IPR2020-1159, IPR2020-1160, IPR2020-
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`1161, and IPR2020-1162. I was previously admitted pro hac vice in IPR
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`proceeding IPR2020-00451, IPR2020-1070, IPR2020-1071, IPR2020-1099,
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`IPR2020-1102 and IPR2020-1103. (Id. at ¶ 6.)
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`7.
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`I am a litigation attorney with 20 years of experience representing
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`clients in patent cases involving a variety of technologies including computer
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`networking and wireless communications, and software technologies. I regularly
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`litigate patent cases in federal district courts and have been involved in various
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`phases of litigation including claim construction, summary judgment, and expert
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`discovery and trial.
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`8.
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`I have an established familiarity with the subject matter at issue in this
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`proceeding. Specifically, I am familiar with the technology and issued claims in
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`2
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`3G EXHIBIT 2003
`IPR2020-01157
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`U.S. Patent No. 7,274,933 (the “’933 patent”). I am also familiar with the prior art
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`references cited by Petitioners in this proceeding and the alleged grounds of
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`invalidity. I also participated in drafting the Patent Owner’s Preliminary Response
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`in this proceeding. Moreover, I have engaged and will continue to engage in
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`extensive strategic and substantive discussions regarding this proceeding with
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`Timothy Devlin, who is a registered practitioner and the lead counsel for Patent
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`Owner in this proceeding.
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`9.
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`I hereby declare that all statements made 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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`I further declare 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 the Title 18 of the United States Code.
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`10.
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`I executed this declaration on May 7, 2021, in Chicago, Illinois.
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`Dated: May 7, 2021
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`Respectfully submitted,
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`/s/Neil Benchell
`Neil Benchell
`Devlin Law Firm LLC
`1526 Gilpin Avenue
`Wilmington, Delaware 19806
`Tel: (302) 449-9010
`Fax: (302) 353-4251
`nbenchell@devlinlawfirm.com
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`
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