UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD .
`
`TRULIA, INC.
`Petitioner
`
`V.
`
`ZILLOW, INC.
`Patent Owner
`
`Case CBM2013-00056
`
`Patent 7,970,674
`
`PATENT OWNER ZILLOW, INC.’S
`MOTION FOR PRO HAC WCE ADMISSION
`
`UNDER 3 7 C.F.R. § 42.10
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`56920-8902. USOO/LEGAL27988090.1
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`

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`The Patent Owner ("Zillow") respectfully requests that the Board recognize
`
`Mr. Ramsey M. Al-Salam as counsel pro hac vice during this proceeding. Zillow
`
`seeks Mr. Al—Salam's assistance because of his experience assisting Zillow on
`
`patent-related matters and his experience on the substantive and technical issues
`
`involved in this proceeding. This motion is authorized by the Notice of Filing Date
`
`Accorded to Petition and Time for Filing Patent Owner Preliminary Response
`
`entered on September 18, 2013.
`
`1.
`
`Statement of Facts
`
`Mr. Al-Salam is an experienced patent litigation attorney, with almost 30
`
`years of experience in discovery, jury and bench trials, Markman hearings, and
`
`appellate oral arguments
`
`in patent
`
`infringement matters. Mr. Al—Salam's
`
`biography, including a list of representative cases, is attached as Exhibit A.
`
`US. Patent No. 7,970,674 is currently involved in pending litigation against
`
`Trulia Inc. in the US. District Court for the Western District of Washington (civil
`action no. 2:12-cv-01549). Zillow is represented by Susman Godfrey LLP in this
`
`litigation; Mr. Al-Salam is not representing Zillow in the litigation. Accordingly,
`
`protective orders in the litigation do not apply to Mr. Al-Salam.
`
`US. Patent No. 7,970,674 is currently involved in a pending Inter Partes
`
`Review (Case No. lPR2013-00034) before the Patent Trial and Appeal Board. Mr.
`
`Al-Salam has been admitted to appear as counsel pro hac vice in the pending Inter
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`56920~8902. USOO/LEGAL27988090.1
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`Partes Review of US. Patent No. 7,970,674 and currently represents Zillow as
`
`back-up counsel in that proceeding.
`
`Furthermore, Mr. Al-Salam has advised Zillow on various patent issues and
`
`has appeared as lead counsel for Zillow in multiple patent cases, including:
`
`1. Smarter Agent v Boopsie, et al., No. 1:10-cv-00245-JJF—LPS (D. Del.)
`
`2. Traffic Information v. Bank ofAmerica, et al. , N0. 2:11—cv-OO343-MHS—
`CMC (ED. Tex.)
`
`3. IZZ Technology v. Mcrosoft, et al., No. 3:11-cv~01103-AC (D. Or.)
`
`4. Earthcomber v. Zillow, No. 1:12—cv-00394-JHL (ND. Ill.)
`
`5. Ceats v. Zillow, No. 6:12-cv—00082-LED (E.D. Tex.)
`
`Mr. Al-Salam was also lead counsel
`
`for Fiserv,
`
`Inc.
`
`in Corelogic
`
`Information Solutions v. Fiserv, Inc, et. al., Case No. 2:10-cv-00132-RSP (ED.
`
`Tex.), which involved automatic valuation techniques similar to those described in
`
`the ‘674 patent were at issue. Accordingly, Mr. Al-Salam is knowledgeable about
`
`the technology to which this proceeding relates.
`
`Therefore, there is good cause for the Board to recognize Mr. Al-Salam as
`
`counsel pro hac vice during this proceeding.
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`3.
`
`Affidavit or Declaration of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is accompanied by the required
`
`Affidavit of Mr. Ramsey M. Al—Salam.
`
`J
`By:
`
`Steven D. Lawrenz
`
`
`Registration No. 37,376
`Lead Counsel for Patent Owner
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`56920-8902. USOO/LEGAL27988090.1
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`AFFIDAVIT OF MR. RAMSEY M. AL-SALAM IN SUPPORT OF
`
`MOTION FOR PRO H4C VICE ADMISSION
`
`1, Ramsey M. Al-Salam, being duly sworn and upon oath, hereby attests to
`
`the following:
`
`1.
`
`I am a member in good standing of the Bar of Washington, as well as the
`
`following Federal Courts:
`
`a. US. Supreme Court
`
`b. US. Court of Appeals for the Federal Circuit
`
`0. US. Court of Appeals for the Ninth Circuit
`
`d. US. District Court for the Eastern District of Washington
`
`.e. US. District Court for the District of Colorado
`
`f. US. District Court for the Northern District of Illinois
`
`g. US District Court for the Eastern District of Texas
`
`2.
`
`1 have not been suspended or disbarred from practice before any court or
`
`administrative body;
`
`3.
`
`I have never had an application for admission to practice before any court or
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`administrative body denied;
`
`4.
`
`No sanction or contempt citation has been imposed against me by any court
`
`or administrative body;
`
`56920-8902. USOO/LEGAL27988090.1
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`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 the C.F.R.;
`
`6.
`
`I will be subject to the USPTO Code 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 applied to appear pro hac vice before the Office for IPR2013-00034 on
`
`December
`
`17, 2012 (granted) and CBM2013-00056 (this proceeding) on
`
`October 14, 2013 (conditionally granted); and
`
`8.
`
`I am an experienced litigation attorney, with experience in numerous
`
`lawsuits involving patent
`
`infringement
`
`in District Courts across the country,
`
`including experience in jury and bench trials, Markman hearings, and Federal
`
`Circuit oral arguments in patent infringement litigation.
`
`In particular, I have
`
`represented Patent Owner Zillow Inc. as
`
`lead counsel
`
`in multiple patent
`
`infringement cases. My biography is attached he ,
`
`o as Exhibit A.
`
`
`
`Seattle, WA 98101-3099
`
`Telephone: (206) 3 59—63 85
`Fax: (206) 359—75 85
`
`56920-8902.USOO/LEGAL27988090,1
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`Sworn to and subscribed before me,
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`if EXHIBITA
`
`

`

`Perklns legal (Lot;meet to Great Companies?
`Core .
`
`
`
`1201 Third Avenue
`Suite 4900
`
`' Seattle, WA 98101
`PHONE: 206.359.6385
`
`FAX: 206.359.9000
`
`Ramsey M. Al-Salam | Partner
`
`Ramsey Al—Salam focuses on intellectual property litigation, with a particular
`
`emphasis on patent litigation. He has been lead counsel for large and small clients in
`
`cases throughout the country. He works hard to ensure that he understands his
`
`clients' goals, and pursues them In an efficient and effective manner.
`
`Publications such as Chambers USA (Band One), Best Lawyers in America
`
`and Washington Super Lawyers have repeatedly listed him as a leading practitioner in
`
`his field. Best Lawyers, for example, listed him as the Seattle Intellectual Property
`
`Litigator of the Year for 2011 and 2012.
`
`In addition to his litigation work, Ramsey is a
`
`frequent Speaker on intellectual property and litigation topics, and has been an adjunct
`
`professor at Seattle University, teaching patent and trade secret law, for more than 10
`years.
`
`RAlSalam@perkinscoie.com
`
`REPRESENTATIVE EXPERIENCE
`
`EDUCATION
`
`Patent Litigation
`
`=1 University of California,
`Berkeley School of Law,
`(formerly Boalt Hall), J.D.,
`1983
`
`it University of California,
`Santa Barbara, B.A.,
`Mathematics/Economics,
`
`with highest honors, 1980
`
`BAR ADMISSIONS
`ii Washington
`
`COURT ADMISSIONS
`
`a US. Supreme Court
`it US. Court of Appeals for
`the Federal Circuit
`
`=1 US. Court of Appeals for
`the Ninth Circuit
`=1 US. District Court for the
`Western District of
`
`Transcenic, Inc. v. Google
`US. District Court for the District of Delaware
`
`Representing Google in patent litigation relating to image navigation functionality.
`
`TransData v. CenterPoint, et al.
`US. District Court for the Western District of Oklahoma
`
`Representing multiple utilities in patent litigation relating to electric meters.
`
`Joao Bock v. Cathay Bank, et al.
`US. District Court for the Central District of California, US. District Court for the
`Northern District of Illinois, US. District Court for the Middle District of Florida
`
`Representing various banks in patent litigation cases relating to online banking.
`
`CoreLogic Inc. v. Fiserv, Inc.
`US. District Court for the Eastern District of Texas
`
`Represented Fiserv, Inc. in patent litigation relating to automated valuation models.
`
`API v. Google Inc. et al.
`US. District Court for the Eastern District of Texas
`
`Represented Google in patent litigation relating to a software activation system. Case
`
`

`

`Washington
`U.S. District Court for the
`Eastern District of
`
`Washington
`U.S. District Court for the
`District of Colorado
`U.S. District Court for the
`Northern District of Illinois
`
`U.S. District Court for the
`Eastern District of Texas
`
`Fl
`
`'.J
`
`stayed pending reexamination.
`
`Google Inc. v. Traffic Information, LLC
`U.S. District Court for the District of Oregon
`Represented Google Inc. in a declaratory judgment patent action relating to traffic
`information provided to mapping applications.
`
`Technology Patents LLC v. Deutsche Telekom AG, et al.
`U.S. District Court for the District of Maryland
`'
`Represented T—Mobile USA Inc. in multi-defendant patent litigation relating to SMS and
`MMS messaging systems and methods. Summary judgment of non-infringement
`granted.
`
`Parallel Networks v. Redbox
`U.S. District Court for the Eastern District of Texas
`
`Represented Redbox in patent litigation relating to mobile applications. Summary
`judgment of noninfringement granted.
`
`Smarter Agent v. Zillow, et al.
`
`U.S. District Court for the District of Delaware
`Represented multiple clients in patent litigation relating to mobile real estate
`applications. Case stayed pending reexamination.
`
`F5 Networks, Inc. v. A10 Networks, Inc.
`U.S. District Court for the Eastern District of Washington
`Represented F5 in two patent litigation cases relating to application delivery
`controllers. Cases settled.
`
`I
`
`Realtime Data, LLC v. Packeteer Inc., et al.
`U.S. District Court for the Eastern District of Texas
`
`Represented F5 Networks and Averitt Networks in multi-defendant patent
`litigation case relating to data compression techniques and systems. Case settled
`after argument of summary judgment motions.
`
`DNT, LLC v. Sprint Nextel Corporation, et al.
`U.S. District Court for the Eastern District of Virginia
`Represented T-Mobile USA Inc. in multi-defendant patent litigation relating to wireless
`data cards. Successfully obtained jury verdict and judgment of invalidity and
`noninfringement.
`
`F&G Research Inc. v. Google Inc.
`U.S. District Court for the Southern District of Florida
`
`Represented Google in patent litigation relating to scrolling mouse technology.
`Obtained summaryjudgment of noninfringement and an award of fees and costs.
`
`E-Data Corporation v. Getty Images Inc.
`U.S. District Court for the Western District of Washington
`Represented Getty Images in patent litigation related to downloading of digital data.
`Obtained summary judgment of noninfringement.
`
`aQuantive Inc. v. 24/7 Real Media Inc.
`
`U.S. District Court for the Western District of Washington
`
`Represented aQuantive in action seeking a declaratory judgment of noninfringement
`of a patent relating to the delivery of advertising over the Internet. Obtained summary
`
`

`

`judgment of noninfringement, which was affirmed on appeal.
`
`Flashpoint Technology Inc. v. AT&T Mobility, LLC, et al.
`U.S. District Court for the District of Delaware
`
`Represented T-Mobile USA in patent infringement lawsuit involving numerous patents
`relating to user interfaces in digital cameras and remote phones. Case stayed pending
`reexamination.
`
`Lunareye, Inc. v. AirlQ, Inc.
`U.S. District Court for the Eastern District of Texas
`
`Represented AirlQ in patent infringement action involving GPS technology. Case
`settled.
`
`Trademark Litigation
`
`Unique Beverage v. Talking Rain
`U.S. District Court for the Western District of Washington
`Represented Talking Rain in trademark infringement suit relating to flavored waters.
`Case settled.
`
`Derek Andrew Inc. v. Vital Pharmaceuticals Inc.
`
`U.S. District Court for the Western District of Washington
`Represented Vital Pharmaceuticals in a trademark case relating to the naming of a
`sportswear line. Case settled after defeating preliminary injunction motion.
`
`Silvers v. Google Inc.
`U.S. District Court for the Southern District of Florida
`
`Represented Google in trademark case relating to plaintiffs alleged rights in "Googles"
`for children's entertainment. Case settled.
`
`Mele v. Blizzard Entertainment Inc.
`U.S. District Court for the Northern District of New York
`
`Represented Blizzard Entertainment in trademark action relating to video games.
`Prevailed at trial.
`
`Stockholm Chamber of Commerce IP Arbitration
`
`Represent Outerwall Inc. in dispute with ScanCoin AB over Ownership of intellectual
`
`property portfolio related to coin counting and similar technotogies.
`
`PROFESSIONAL RECOGNITION
`
`=1 Named the Best Lawyers’ Seattle "Litigation - Patent Lawyer of the Year," 2014;
`
`"Seattle Intellectual Property Lawyer of the Year", 2011 - 2012
`
`it Listed in IntellectualAsset Management Patent 1000, "Litigation Gold Band," 2012 -
`2013
`
`=1 Repeatedly listed in Chambers USA for IP litigation ("Band One")
`
`Fl Listed in The Best Lawyers in America 1995 - Present: Litigation — Intellectual
`
`Property; Litigation — Patent
`
`it Washington Law & Politics, "Washington's Top 40 Intellectual Property Lawyers".
`
`"Washington's Top 100 Lawyers" and "Washington's Super Lawyers," 2003 ~ 2013
`
`

`

`PROFESSIONAL LEADERSHIP
`
`it American Bar Association, Patent, Trademark and Copyright Section
`
`it American intellectual Property Law Association
`
`ii Washington Bar Association, Intellectual Property Section
`
`RELATED EMPLOYMENT
`
`ii Seattle University School of Law, Adjunct Professor, Patent and Trade Secret Law,
`1999 - present
`
`I“ University of Washington School of Law, WA, Adjunct Professor, Patent Law, Fall
`2001
`
`7! Seed & Berry, Seattle, WA, Partner, 1995 - 1999; Of Counsel, 1993 - 1995
`
`i1 Bogle & Gates, Seattle, WA, Associate, 1989 - 1993
`
`it Lyon & Lyon, Los Angeles, CA, Associate, 1983 - 1989
`
`PAST EVENTS
`
`12.13.2012 - The 21st Annual Seattle Conference on
`
`12.14.2012 Technology Law
`Speaking Engagement
`Law Seminars international
`
`Washington State Convention Center / Seattle, WA
`
`07.28.2012 General Spoliation Principles and Their
`Application in Patent Cases
`Speaking Engagement
`CASRIP High Technology Protection Summit
`Center for Advanced Study & Research on intellectual
`Property (CASRIP), University of Washington / Seattle, WA
`
`05.17.2012 The intersection of Patent Applications and
`Trade Secrets
`
`Speaking Engagement
`DRI Business Litigation and intellectual Property Seminar/
`New York, NY
`
`03.09.2012 2011 Patent Cases — The Pendulum Begins to
`Move
`
`Speaking Engagement
`WSBA 17th Annual intellectual Property institute / Seattle, WA
`
`11.18.2011 Responding to Patent Claims and Patent
`Trolls
`
`Speaking Engagement
`2011 Corporate Counsel institute / Seattle, WA
`
`05.25.2011 CLE -— E-Discovery — Now What?
`Speaking Engagement
`Topic: "Protocol Development and implementation — How Are
`Courts interpreting the Rules?“
`
`

`

`National Business institute /' Seattle, WA
`
`05.13.2011 Strictly Retail Seminar
`Speaking Engagement
`Topic: "intellectual Property Law for the Retailer”
`DRI — The Voice of the Defense Bar
`
`02.11.2011 Intellectual Property Section Meeting
`Speaking Engagement
`Topic: “Selected Issues in Licensing"
`King County Bar Association
`
`09.11.2010 CLE -- Understanding the Laws of Intellectual
`Property
`Speaking Engagement
`Topic: “Overview of intellectual Property Litigation"
`Washington State Bar Association
`
`07.14.2010 Patent CLE In re Bilski
`Seminar
`
`Perkins Cole’s Seattle Office / Seattle, WA
`
`05.07.2010 Hot Topics in the Parallel Universe of Patent
`Reexamination and Patent Litigation
`Seminar
`
`Perkins Coie LLP / Seattle, WA
`
`Printed March 05, 2014
`
`

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`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of this Motion for Pro Hac Vice
`
`Admission and a copy of the Affidavit of Mr. Ramsey M. AI-Salam in Support'of
`
`Motion for Pro Hac Vice Admission has been served Via overnight courier on
`
`Wupon the following:
`
`Michael T. Rosato, Lead Counsel
`Wilson Sonsini Goodrich & Rosati
`
`701 Fifth Avenue
`
`Suite 5100
`
`Seattle, WA 98104-7036
`
`Jennifer J. Schmidt, Back-Up Counsel
`Wilson Sonsini Goodrich & Rosati
`
`One Market Plaza
`
`Spear Tower, Suite 3300
`San Francisco, CA 94105-1126
`
`Kathleen Retan
`
`Paralegal
`Perkins Coie LLP
`
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`56920-8902.USOO/LEGAL27988090.1
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