`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`APPLE INC.
`Petitioner
`
`v.
`
`SMARTFLASH, LLC
`Patent Owner
`______________
`
`Case CBM2015-00016
`Patent 8,033,458 B2
`______________
`
`
`
`
`
`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 7), Petitioner Apple Inc. (“Apple”) respectfully
`
`requests pro hac vice admission of Lauren N. Robinson as counsel in this
`
`proceeding.
`
`
`
`
`
`Case CBM2015-00016
`Patent 8,033,458 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
`
`October 30, 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. 8,033,458 B2 (“the ‘458
`
`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 CBM2015-00016
`Patent 8,033,458 B2
`District Court litigation—where Smartflash filed its infringement action asserting
`
`the ‘458 Patent and the related U.S. Patent Nos. 7,334,720; 7,942,317; 8,061,598;
`
`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
`
`Respectfully submitted,
`By: /J. Steven Baughman/
`
`J. Steven Baughman, Lead Counsel
`Ching-Lee Fukuda
`ROPES & GRAY LLP
`
`counsel pro hac vice.
`
`
`
`Dated: December 3, 2014
`
`
`
`
`-3-
`
`
`
`Case CBM2015-00016
`Patent 8,033,458 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-
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