`
`
`Filed on behalf of:
`
`Petitioner
`By: Megan Thisse O’Gara (Lead Counsel)
` Megan.OGara@Troutman.com
`
`Nicholas J. Gallo (First Back-up Counsel)
`
`Nicholas.Gallo@Troutman.com
`
`Paper No. ____
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
`
`CONTENT SQUARE SAS,
`Petitioner,
`
`v.
`
`MEDALLIA INC.,
`Patent Owner.
`_________________
`
`Case IPR2022-00316
`Patent 8,886,552
`_________________
`
`
`
`DECLARATION OF NICHOLAS J. GALLO
`
`
`
`
`
`
`Content Square 1009
`Content Square v Medallia Inc.
`IPR2022-00316
`
`
`
`
`
`
`
`120930615
`
`
`
`IPR2022-00316 (Patent 8,886,552)
`Declaration of Nicholas J. Gallo
`
`
`I, NICHOLAS J. GALLO, HEREBY DECLARE
`
`1.
`
`I am an attorney duly licensed to practice law in the State of New
`
`York. I am a patent attorney registered to practice before the U.S. Patent and
`
`Trademark Office. I am an attorney at the law firm of Troutman Pepper Hamilton
`
`Sanders LLP. This declaration is based upon my personal knowledge of the
`
`matters set forth herein.
`
`2.
`
`I submit this declaration with Petitioner’s Petition for Inter Partes
`
`Review of U.S. Patent No. 8,886,552 being filed concurrently herewith. The
`
`purpose of this declaration is to authenticate Exhibits 1010, 1011, 1012, and 1013.
`
`3.
`
`Exhibit 1010 is a true and correct copy of the Order Granting Joint
`
`Motion to Stay filed December 27, 2021 in Medallia Inc. v. Content Square SAS,
`
`Civil Docket for Case #: 6:21-cv-00532-ADA (W.D. Tex.) [DI 50], as retrieved
`
`from the Court’s public docket.
`
`4.
`
`Exhibit 1011 is a true and correct copy of analytics available through
`
`Lex Machina regarding the pending case load for patent cases before Judge Alan
`
`D. Albright in the Western District of Texas. The analytics shown in Exhibit 1011
`
`were retrieved by querying Lex Machina for patent cases before Judge Albright
`
`between December 14, 2017 and December 14, 2021 (i.e., approximately the last
`
`four years).
`
`120930615
`
`2
`
`
`
`IPR2022-00316 (Patent 8,886,552)
`Declaration of Nicholas J. Gallo
`
`
`5.
`
`Exhibit 1012 is a true and correct copy of the docket for Case No.
`
`6:21-cv-00532-ADA (W.D. Tex.) as of December 28, 2021.
`
`6.
`
`Exhibit 1013 is a true and correct copy of the Agreed Scheduling
`
`Order filed November 8, 2021 in Case No. 6:21-cv-00532-ADA (W.D. Tex.) [DI
`
`47], as retrieved from the Court’s public docket.
`
`7.
`
`I hereby declare under penalty of perjury that the foregoing is true and
`
`correct, that all statements made herein of my own knowledge are true, and that all
`
`statements made on information and belief are believed to be true; and further 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 18 U.S.C.
`
`§ 1001 and may jeopardize the validity of the application or any patent issuing
`
`thereon. If called to testify as to the truth of the matters stated herein, I could and
`
`would testify competently.
`
`Dated: December 30, 2021
`
`
`
`
`
`/Nicholas J. Gallo/
`Nicholas J. Gallo
`Registration No. 60,758
`
`
`
`
`
`
`
`120930615
`
`3
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
