UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`CRS ADVANCED TECHNOLOGIES, INC.
`Petitioner
`
`v.
`
`Patent of FRONTLINE TECHNOLOGIES, INC.
`Patent Owner
`_______________
`
`Case CBM2012-00005
`Patent 6,675,151C1
`_______________
`
`PETITIONER CRS ADVANCED TECHNOLOGIES, INC.’s
`MOTION FOR ADMISSION PRO HAC VICE
`OF DARREL C. KARL
`
`
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`CRS ADVANCED TECHNOLOGIES, INC.
`Petitioner
`
`v.
`
`Patent of FRONTLINE TECHNOLOGIES, INC.
`Patent Owner
`_______________
`
`Case CBM2012-00005
`Patent 6,675,151C1
`_______________
`
`PETITIONER CRS ADVANCED TECHNOLOGIES, INC.’s
`MOTION FOR ADMISSION PRO HAC VICE
`OF DARREL C. KARL
`
`
`
`Case CBM2012-00005
`Patent 6,675,151C1
`Attorney Docket No.: 09461-0004
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`I. Relief Requested
`
`Pursuant to 37 C.F.R. § 42.10, Petitioner, CRS Advanced Technologies, Inc.,
`
`requests that the Board admit Darrel C. Karl pro hac vice in this proceeding.
`
`II. Statement of Facts Showing There is Good Cause for the Board to
`Recognize Counsel Pro Hac Vice During the Proceeding
`
`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel pro hac
`
`vice during a proceeding upon a showing of good cause, subject to the condition
`
`that lead counsel be a registered practitioner and to any other conditions as the
`
`Board may impose. Section 42.10(c) indicates that, “where lead counsel is a
`
`registered practitioner, a motion to appear pro hac vice may be granted upon a
`
`showing that counsel is an experienced litigating attorney and has an established
`
`familiarity with the subject matter at issue in the proceeding.” The facts here
`
`establish good cause for the Board to recognize Darrel C. Karl pro hac vice during
`
`this proceeding.
`
`1.
`
`Lead counsel, E. Robert Yoches, is a registered practitioner.
`
`2. Counsel, Darrel C. Karl, is an experienced litigating attorney and has
`
`an established familiarity with the subject matter at issue in the proceeding.
`
`
`
`1
`
`
`
`Accompanying this motion is the Declaration of Darrel C. Karl in Support of
`
`Case CBM2012-00005
`Patent 6,675,151C1
`Attorney Docket No.: 09461-0004
`
`
`Motion for Admission Pro Hac Vice (“Karl Declaration”). In the Karl Declaration,
`
`Mr. Karl states, inter alia, that: “I am a member in good standing of the Bars of the
`
`State of Maryland and the District of Columbia and am also admitted to practice in
`
`the U.S. Court of Appeals for the Federal Circuit and in the U.S. Supreme Court. I
`
`am currently admitted to practice pro hac vice in the U.S. District Court for the
`
`Eastern District of Pennsylvania. I have been in private practice since 1986, and
`
`have been litigating patent cases continuously since that time.” Karl Declaration at
`
`¶ 2.
`
`3. Mr. Karl also states that: “I am very familiar with the subject matter at
`
`issue in this proceeding. I am counsel for Defendant CRS in the Frontline
`
`Technologies, Inc. v. CRS, Inc. patent infringement litigation, Civil Action No.
`
`2:07-cv-2457 (E.D. Pa.), which involves the same patent at issue in this
`
`proceeding. Since that lawsuit was filed in 2007, I have been responsible for the
`
`day-to-day management and conduct of that litigation for my client. I have drafted
`
`in whole or in part every substantive paper filed in that litigation, defended every
`
`deposition of CRS witnesses and experts, and personally deposed of all but two of
`
`Frontline’s witnesses and experts.” Id. at ¶ 10.
`
`
`
`2
`
`
`
`Case CBM2012-00005
`Patent 6,675,151C1
`Attorney Docket No.: 09461-0004
`
`
`In the Karl Declaration, Mr. Karl attests, inter alia, that he has read
`
`4.
`
`and will comply with Office Patent Trial Practice Guide and the Board’s Rules of
`
`Practice for Trials, and agrees to be subject to the United States Patent and
`
`Trademark Office Code of Professional Responsibility set forth in 37 C.F.R. §§
`
`10.20 et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a). Karl
`
`Declaration at ¶¶ 7-8.
`
`III. Conclusion
`
`For the foregoing reasons, Petitioner, CRS Advanced Technologies, Inc.,
`
`respectfully requests that the Board admit Darrel C. Karl pro hac vice in this
`
`proceeding.
`
`
`
`Dated: January 29, 2013
`
`Respectfully submitted,
`
`
`
`
`By: /s/ E. Robert Yoches
`E. Robert Yoches, Reg. No. 30,120
`Aaron J. Capron, Reg. No. 56,170
`Finnegan, Henderson, Farabow,
` Garrett & Dunner, L.L.P.
`901 New York Avenue, N.W.
`Washington, D.C. 20001-4413
`Phone: (202) 408-4000
`Fax: (202) 408-4400
`
`Attorneys for Petitioner
`CRS Advanced Technologies, Inc.
`
`
`
`3
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 29th day of January, 2013, a true and correct
`
`copy of the foregoing PETITIONER CRS ADVANCED TECHNOLOGIES,
`
`INC.’s MOTION FOR ADMISSION PRO HAC VICE OF DARREL C. KARL
`
`and DECLARATION OF DARREL C. KARL IN SUPPORT OF MOTION FOR
`
`ADMISSION PRO HAC VICE, were served via electronic mail and overnight
`
`courier upon the following counsel of record for Patent Owner Frontline
`
`Technologies, Inc.:
`
`John P. Donohue, Jr., Lead Counsel
`Woodcock Washburn, LLP
`Cira Centre – 12th Floor
`2929 Arch Street
`Philadelphia, PA 19103
`Phone: 215.568.3100
`Fax: 215.568.3439
`Email: donohue@woodcock.com
`
`John E. McGlynn, Back-up Counsel
`Woodcock Washburn, LLP
`Cira Centre – 12th Floor
`2929 Arch Street
`Philadelphia, PA 19103
`Phone: 215.564.8382
`Fax: 215.568.3439
`Email: mcglynn@woodcock.com
`
`
`/s/ Jacob Mersing
`Jacob Mersing
`Legal Assistant
`Finnegan, Henderson, Farabow,
` Garrett & Dunner, L.L.P.
`4
`
`
`
`
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