`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`EBATES PERFORMANCE MARKETING, INC. DBA RAKUTEN
`REWARDS
`Petitioners,
`
`v.
`
`INTERNATIONAL BUSINESS MACHINES, INC.
`Patent Owner.
`
`
`
`U.S. Patent No. 7,543,234 to Daniels et al.
`
`IPR Case No. IPR2022-00133
`
`
`
`
`
`DECLARATION OF ALLAN A. KASSENOFF IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
`
`
`
`
`
`Patent No. 7,543,234
`IPR2022-00133
`
`Pursuant to 37 C.F.R. § 1.68, I, Allan A. Kassenoff, attest to the following:
`
`
`
`1. I am a shareholder of Greenberg Traurig, LLP and a member in good standing
`
`in the bar of New York, bar of New Jersey, the U.S. District Court of Appeals for
`
`the Federal Circuit, and several U.S. District Courts.
`
`2. I have not been suspended or disbarred from practice before any court or
`
`administrative body.
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`3. I have never had an application for admission to practice before any court or
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`administrative body denied.
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`4. No sanction or contempt citation has been imposed against me by any court
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`or administrative body.
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`5. I have read and will comply with the Office Patent Trial Practice Guide and
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`the Board’s Rules of Practice for Trials set forth in Part 42 of Title 37, Code of
`
`Federal Regulations.
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`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).
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`7. In the last three years, I have not applied to appear pro hac vice before the
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`Office.
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`8. I am counsel for Petitioner in the related litigation of International Business
`
`Machines Corporation v. Rakuten, Inc., Rakuten USA Inc., Rakuten Commerce, LLC
`
`2
`
`
`
`
`
`Patent No. 7,543,234
`IPR2022-00133
`
`
`and Ebates Inc. dba Rakuten, 1:21-cv-00461-LPS (D. Del.). I am an experienced
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`litigation attorney and have been involved in numerous patent infringement cases in
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`federal courts across the country. I have twenty-four (24) years of patent litigation
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`experience. I have experience in various aspects of patent infringement matters,
`
`including all aspects of litigation leading up to and including jury trials.
`
`9. I have obtained substantial familiarity with the involved patent, the prior art,
`
`and the various issues raised in this proceeding. I am familiar with the subject matter
`
`involved in this proceeding and have reviewed the Petition and the cited materials.
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`10. I declare that all statements made herein of my own knowledge are true and
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`that all statements made on information and belief are believed to be true; and further
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`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 Section 1001
`
`of Title 18 of the United States Code.
`
`
`
`Date: June 13, 2022
`
`
`
`
`
`
`
`
`
`/s/ Allan A. Kassenoff
`Allan A. Kassenoff
`Greenberg Traurig, LLP
`One Vanderbilt Avenue
`New York, NY 10017
`Telephone: 212-801-2157
`Facsimile: 212-801-6400
`KassenoffA@gtlaw.com
`
`3
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`
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