`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
`
`ZYNGA INC.,
`Petitioner,
`v.
`IGT,
`Patent Owner.
`
`____________________________
`
`U.S. Patent No. 8,266,212
`
`Case No. IPR2022-00368
`__________________________________________________________________
`
`DECLARATION OF CLEMENT ROBERTS IN SUPPORT OF
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE
`__________________________________________________________________
`
`Zynga Ex. 1027, p. 1
` Zynga v. IGT
` IPR2022-00368
`
`
`
`I, Clement Roberts, hereby declare as follows:
`
`1.
`
`I am currently an attorney at Orrick, Herrington, & Sutcliffe LLP. I
`
`am member in good standing of the State Bar of California. I was admitted to
`
`the California State Bar on April 6, 2001. My California Bar membership
`
`number is 209203. I am admitted to practice before the District Courts of the
`
`Northern, Central and Southern Districts of California as well as the Eastern
`
`District of Texas. I am also admitted to practice before the U.S. Court of Appeals
`
`for the Federal Circuit and the U.S. Supreme Court. Since 2001, I have practiced
`
`in the field of intellectual property litigation, particularly patent litigation.
`
`2.
`
`I have never been suspended or disbarred from practice before any
`
`court or administrative body.
`
`3.
`
`I have never had a court or administrative body deny my application
`
`for admission to practice.
`
`4.
`
`I have never had any sanctions or contempt citations imposed on me
`
`by any court or administrative body.
`
`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 part 42 of 37
`
`C.F.R.
`
`Zynga Ex. 1027, p. 2
` Zynga v. IGT
` IPR2022-00368
`
`
`
`6.
`
`I agree to be subject to the United States Patent and Trademark
`
`Office 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 have previously applied to appear pro hac vice before the office in
`
`IPR2020-01267, -01280, -01332, and -01359.
`
`8.
`
`I am an experienced litigation attorney, with particular experience in
`
`patent infringement litigations in district courts across the country, including
`
`experience with fact and expert deposition discovery, claim construction, Markman
`
`hearings, motion practice, trials, and hearings.
`
`9.
`
`I am familiar with the subject matter at issue in this proceeding and in
`
`a related district court litigation where U.S. Patent No. 8,266,212 had been asserted
`
`by the Patent Owner: IGT et al. v. Zynga Inc., Case No. 6:21-cv-00331-ADA (W.D.
`
`Tex., filed April 6, 2021). I also am familiar with the prior art raised in this
`
`proceeding, including U.S. Patent Publication 2001/0044339 to Cordero, et al. (Ex.
`
`1004) and U.S. Patent 5,187,787 to Skeen et al. (Ex. 1005). I have reviewed the
`
`briefs and papers filed in this proceeding.
`
`10.
`
`I declare that all statements made herein of my own knowledge are true
`
`and correct 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
`
`Zynga Ex. 1027, p. 3
` Zynga v. IGT
` IPR2022-00368
`
`
`
`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.
`
`Dated:
`
`12/2/2022
`
`/Clement Roberts/
`Clement Roberts
`ORRICK, HERRINGTON, &
`SUTCLIFFE LLP
`The Orrick Building
`405 Howard Street
`San Francisco, CA 94105-2669
`Tel: 415 773 5577
`Email: croberts@orrick.com
`
`Zynga Ex. 1027, p. 4
` Zynga v. IGT
` IPR2022-00368
`
`
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