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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`HEWLETT-PACKARD COMPANY,
`Petitioner
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`v.
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`YYZ, LLC,
`Patent Owner
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`CBM2015-00050
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`MOTION FOR PRO HAC VICE ADMISSION OF MATTHEW FAUST
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`U.S. PATENT NO. 7,603,674
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` Pursuant to 37 C.F.R. § 42.10(c), and as authorized in the Board’s Notice of
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`Filing Date Accorded to Petition (Paper 3), Petitioner Hewlett-Packard Co. (“HP”)
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`respectfully requests pro hac vice admission of Matthew Faust as backup counsel
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`in this proceeding.
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`I.
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`Time for Filing
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`This motion is timely because it is being filed no sooner than twenty one (21)
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`days after service of the Petition in this proceeding.
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`Statement of Facts
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`II.
`The following statement of facts demonstrates that there is good cause for the
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`Board to recognize Matthew Faust as counsel pro hac vice in this proceeding.
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`Mr. Faust is an experienced litigation attorney and has extensive experience
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`litigating patent infringement actions in many different District Court cases. Mr.
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`Faust is admitted to practice law in New York, and federal court in the Southern
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`District of New York and the Eastern District of Michigan.
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`Mr. Faust has an established familiarity with the subject matter at issue in this
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`proceeding. Mr. Faust has been representing HP against Patent Owner YYZ, LLC
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`(“YYZ”) as counsel since January 2013 in a related District Court case currently
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`pending in the District of Delaware, YYZ, LLC v. Hewlett-Packard Co., No. 1:13-
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`cv-00136-SLR (D. Del.). In this related proceeding, YYZ has asserted U.S. Patent
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`No. 7,603,674 (“the ’674 patent”) against HP. As counsel in this related
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`proceeding, Mr. Faust has, among other things, been heavily involved with
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`analyzing validity of the ’674 patent. Accordingly, HP requests that Mr. Faust
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`continue as counsel in this CBM proceeding as well.1
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`III. Declaration of Matthew Faust
`As directed by the Board in the Order Authorizing Pro Hac Vice Admission in
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`Case IPR2013-00639, Paper 7 (“Representative Order”),
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`this motion
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`is
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`accompanied by the Declaration of Matthew Faust (Ex. 1035) attesting to the
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`requirements laid out in the Representative Order.
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`For the foregoing reasons, HP respectfully requests admission of Mr. Faust as
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`counsel pro hac vice in this proceeding.
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`January 30, 2015
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` Respectfully submitted,
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`/Brian S. Mudge/____________
` By:
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` Brian S. Mudge (Reg. No. 40,738)
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` Lead Counsel for Petitioner
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` Matthew Faust
`Adeel Haroon (Reg. No. 64,938)
` Backup Counsel for Petitioner
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` Petitioner is concurrently filing a motion for pro hac vice admission of Matthew
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`Faust in CBM2015-00049, which involves the same parties as the instant
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`proceeding.
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`2
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that the foregoing Motion for Pro Hac Vice
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`Motion of Matthew Faust and associated Exhibit were served via Express Mail
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`upon the following:
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`Courtesy copy to:
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`Brian E. Farnan
`Farnan LLP
`919 N. Market Street, 12th Floor
`Wilmington, DE 19801
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`Date: January 30, 2015
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`KENYON & KENYON LLP
`1500 K Street, NW
`Washington, DC 20005-1257
`Tel: 202.220.4200
`Fax: 202.220.4201
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`Julie Chovanes
`Chovanes Law LLC
`Suite 329
`5 Great Valley Parkway
`Malvern, PA 19355
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`James F. McDonough, III
`HENINGER GARRISON DAVIS, LLC
`3621 Vinings Slope, Suite 4320
`Atlanta, GA 30339
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` By: /Brian S. Mudge/
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` Brian S. Mudge (Reg. No. 40,738)
`Lead Counsel for Petitioner
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