UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`APPLE INC.
`Petitioner
`
`v.
`
`SMARTFLASH, LLC
`Patent Owner
`______________
`
`Case CBM2014-001081
`Patent 8,061,598 B2
`______________
`
`Before JENNIFER S. BISK, RAMA G. ELLURU, NEIL T. POWELL, JEREMY
`M. PLENZLER, and MATTHEW R. CLEMENTS, Administrative Patent Judges.
`
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`LAUREN N. ROBINSON
`
`Pursuant to Rule 42.10(c), and as authorized in the Board’s Notice of Filing
`
`Date Accorded to Petition (Paper 3), Petitioner Apple Inc. (“Apple”) respectfully
`
`requests pro hac vice admission of Lauren N. Robinson as counsel in this
`
`proceeding.
`
`
`
`
`1 Case CBM2014-00109 has been consolidated with the instant proceeding.
`
`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`APPLE INC.
`Petitioner
`
`v.
`
`SMARTFLASH, LLC
`Patent Owner
`______________
`
`Case CBM2014-001081
`Patent 8,061,598 B2
`______________
`
`Before JENNIFER S. BISK, RAMA G. ELLURU, NEIL T. POWELL, JEREMY
`M. PLENZLER, and MATTHEW R. CLEMENTS, Administrative Patent Judges.
`
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`LAUREN N. ROBINSON
`
`Pursuant to Rule 42.10(c), and as authorized in the Board’s Notice of Filing
`
`Date Accorded to Petition (Paper 3), Petitioner Apple Inc. (“Apple”) respectfully
`
`requests pro hac vice admission of Lauren N. Robinson as counsel in this
`
`proceeding.
`
`
`
`
`1 Case CBM2014-00109 has been consolidated with the instant proceeding.
`
`
`
`Case CBM2014-00108
`Patent 8,061,598 B2
`
`I.
`
`Time for Filing
`
`This Motion is timely because it is being filed no sooner than twenty one
`
`(21) days after service of the Petition in this proceeding, which occurred on April
`
`1, 2014.
`
`II.
`
`Statement of Facts
`
`The following statement of facts demonstrates that there is good cause for
`
`the Board to recognize Lauren N. Robinson as counsel pro hac vice in this
`
`proceeding.
`
`Ms. Robinson is an experienced litigation attorney and has an established
`
`familiarity with the subject matter at issue in this proceeding. Ms. Robinson has
`
`been practicing law since 2008 and has extensive experience litigating patent
`
`infringement cases in different District Courts across the country. Among her
`
`experience in patent litigation matters, Lauren N. Robinson has participated in
`
`multiple trials, Markman hearings, and other patent-related hearings and pleadings
`
`concerning, inter alia, patent validity and infringement issues. Ms. Robinson has
`
`also been recognized as a leading patent litigation attorney, including as a Northern
`
`California Super Lawyers Rising Star (2010, 2013, 2014).
`
`Ms. Robinson is familiar with U.S. Patent No. 8,061,598 B2 (“the ‘598
`
`Patent”) and the issues involved in this case. Ms. Robinson has been representing
`
`Apple against Patent Owner Smartflash LLC (“Smartflash”) as counsel in pending
`
`
`
`
`-2-
`
`
`
`Case CBM2014-00108
`Patent 8,061,598 B2
`District Court litigation—where Smartflash filed its infringement action asserting
`
`the ‘598 Patent and the related U.S. Patent Nos. 7,334,720; 7,942,317; 8,033,458;
`
`8,118,221; and 8,336,772 against Apple—since 2013, and has been actively
`
`involved as counsel for Apple since that time. As counsel in the District Court
`
`litigation, Ms. Robinson has, among other things, been heavily involved with
`
`forming invalidity positions against Smartflash’s patents. Accordingly, Apple
`
`prefers that Ms. Robinson continue as counsel in this CBM proceeding as well;
`
`and, further, Smartflash does not oppose Ms. Robinson’s admission pro hac vice.
`
`III.
`
`Declaration of Lauren N. Robinson
`
`As directed by the Board, this Motion is also accompanied by the
`
`Declaration of Lauren N. Robinson in Support of Motion for Pro Hac Vice
`
`Admission attesting to the requirements laid out in the Board’s Order Authorizing
`
`Motion for Pro Hac Vice Admission in Case IPR2013-00639 (Paper 7).
`
`For the foregoing reasons as well as the reasons contained in the attached
`
`declaration, Apple respectfully requests admission of Lauren N. Robinson as
`
`counsel pro hac vice.
`
`
`
`
`
`Dated: December 3, 2014
`
`Respectfully submitted,
`By: /J. Steven Baughman/
`
`J. Steven Baughman, Lead Counsel
`Ching-Lee Fukuda
`ROPES & GRAY LLP
`
`
`
`
`-3-
`
`
`
`Case CBM2014-00108
`Patent 8,061,598 B2
`
`Prudential Tower
`800 Boylston Street
`Boston, Massachusetts 02199-3600
`Steven.baughman@ropesgray.com
`Ching-Lee.fukuda@ropesgray.com
`
`Attorneys for Petitioner Apple Inc.
`
`
`
`
`
`
`
`-4-
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`APPLE INC.
`Petitioner
`
`v.
`
`SMARTFLASH, LLC
`Patent Owner
`______________
`
`Case CBM2014-001082
`Patent 8,061,598 B2
`______________
`
`
`
`Before JENNIFER S. BISK, RAMA G. ELLURU, NEIL T. POWELL, JEREMY
`M. PLENZLER, and MATTHEW R. CLEMENTS, Administrative Patent Judges.
`
`DECLARATION OF LAUREN N. ROBINSON IN SUPPORT OF MOTION
`FOR PRO HAC VICE ADMISSION
`
`I, Lauren N. Robinson, being duly sworn and upon oath, hereby attest to the
`
`following:
`
`1.
`
`2.
`
`I am a member in good standing of the Bar of California.
`
`I have never been suspended or disbarred from practice before any court or
`
`administrative body.
`
`3.
`
`I have never been denied an application for admission to practice before any
`
`court or administrative body.
`
`2 Case CBM2014-00109 has been consolidated with the instant proceeding.
`
`
`
`Case CBM2014-00108
`Patent 8,061,598 B2
`No sanction or contempt citation has ever been imposed against me by any
`
`4.
`
`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 the Code of Federal
`
`Regulations.
`
`6.
`
`I will be subject to the USPTO 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.
`
`In the last three (3) years, I have applied to appear pro hac vice before the
`
`Office in CBM2013-00020 (filed 3/24/2014 (Paper No. 55), granted 4/2/2014
`
`(Paper No. 63)) and CBM2013-00023 (filed 3/24/2014 (Paper No. 52), granted
`
`4/2/2014 (Paper No. 59)), also representing Apple.
`
`8.
`
`Concurrently with the present motion, I intend to file a motion to apply to
`
`appear pro hac vice before the Office in CBM2014-00102, CBM2014-00106,
`
`CBM2014-00112, CBM2015-00015, CBM2015-00016, CBM2015-00017, and
`
`CBM2015-00018, also involving Apple and Smartflash.
`
`9.
`
`I am an experienced litigation attorney having familiarity with the subject
`
`matter at issue in this proceeding. I have been practicing law since 2008 and have
`
`extensive experience litigating patent infringement cases in many different District
`
`Courts across the country, including participation in multiple trials, Markman
`
`hearings, and other patent-related hearings and pleadings concerning, inter alia,
`
`
`
`
`-2-
`
`
`
`Case CBM2014-00108
`Patent 8,061,598 B2
`patent validity and/or infringement. I have received professional recognition in the
`
`field of patent litigation, including as a Northern California Super Lawyers Rising
`
`Star (2010, 2013, 2014). I am very familiar with U.S. Patent No. 8,061,598 (“the
`
`‘598 Patent”) and the issues involved in this case. I have represented Apple
`
`against Smartflash in the pending District Court litigation since 2013, and have
`
`been actively involved as counsel for Apple since that time. As counsel in the
`
`District Court litigation, I have, among other things, been heavily involved with
`
`forming invalidity positions against Smartflash’s ‘598 patent and related patents.
`
`
`
`I declare under penalty of perjury that the foregoing is true and correct. Executed
`
`this 3rd day of December, 2014, in East Palo Alto, CA.
`
`
`
`
`
`
`
`
`
`
`
`/s/ Lauren N. Robinson
`Lauren N. Robinson
`
`
`
`
`
`
`-3-
`
`
`
`CERTIFICATE OF SERVICE
`
`Case CBM2014-00108
`Patent 8,061,598 B2
`
`The undersigned certifies that a copy of the foregoing UNOPPOSED
`
`MOTION FOR PRO HAC VICE ADMISSION OF LAUREN N. ROBINSON and
`
`DECLARATION OF LAUREN N. ROBINSON IN SUPPORT OF MOTION
`
`FOR PRO HAC VICE ADMISSION was served on December 3, 2014, to the
`
`following Counsel for Patent Owner via e-mail, pursuant to the parties’ agreement
`
`concerning service:
`
`
`Michael R. Casey
`J. Scott Davidson
`DAVIDSON BERQUIST JACKSON & GOWDEY LLP
`4300 Wilson Blvd, Suite 700
`Arlington, VA 22203
`Telephone: (703) 894-6406
`Facsimile: (703) 894-6430
`mcasey@dbjg.com
`jsd@dbjg.com
`docket@dbjg.com
`
`Attorneys for Patent Owner
`Smartflash, LLC
`
`
`
` /s/ Lauren N. Robinson
`Lauren N. Robinson
`
`ROPES & GRAY LLP
`
`
`
`
`
`
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