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UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`IBG LLC,
`INTERACTIVE BROKERS LLC, TRADESTATION GROUP, INC.
`TRADESTATION SECURITIES, INC.,
`TRADESTATION TECHNOLOGIES, INC., and IBFX, INC.,
`Petitioner
`
`V.
`
`TRADING TECHNOLOGIES INTERNATIONAL, INC.
`Patent Owner
`
`Case CBM2015-00181
`Patent No. 7,676,411
`
`PETITIONER’S
`UNOPPOSED MOTION FOR PRO HAG VICE ADMISSION
`UNDER 37 C.F.R. § 42.10(c)
`
`

`
`Proceeding No.: CBM2015-00181
`Patent No. 7,676,411
`
`Pursuant to 37 C.F.R. § 42.10(c), the Petitioner ("TradeStation Group, Inc.
`
`and TradeStation Securities Inc.") respectfully requests that the Board recognize
`
`Adam J. Kessel as counsel pro hac vice in this proceeding. Petitioner seeks the
`
`counsel of Adam J. Kessel due to his experience in representing Petitioner in other
`
`patent-related matters and particularly due to his familiarity with 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 that was mailed on September 30, 2015.
`
`Statement of Facts
`
`Mr. Kessel is a patent litigation attorney with more than a decade of
`
`experience representing clients in cases involving computer software. Mr. Kessel
`
`regularly litigates cases before the United States Court of Appeals for the Federal
`
`Circuit, various federal district courts, and the International Trade Commission.
`
`Through his practice in such cases, Mr. Kessel has gained substantial experience in
`
`jury trials, discovery, Markrnan hearings, and appeals. In addition to his legal
`
`experience, Mr. Kessel had many years of software development experience prior
`
`to entering the practice of law. Mr. Kessel also has a degree in chemistry from
`
`Princeton University. TradeStation Group, Inc and TradeStation Securities, Inc.
`
`

`
`Proceeding No.: CBM2015-00181
`Patent No. 7,676,411
`
`provides Adam Kessel’s biography as Exhibit A of the Declaration of Adam
`
`Kessel, as evidence.
`
`Mr. Kessel also has particular experience and familiarity with the
`
`substantive and technical issues involved in this Covered Business Method review
`
`proceeding. Mr. Kessel has been involved in co-pending patent litigation brought
`
`by Patent Owner against Petitioner since its inception in June 2010. Over the past
`
`five years, Mr. Kessel has invested substantial time on Petitioner’s behalf on
`
`motion practice, discovery, appeals, and analysis of the twelve patents-in-suit,
`
`including the patent for which review is sought in the instant proceeding. Petitioner
`
`has thus invested significant financial resources in this related matter in which Mr.
`
`Kessel served as Petitioner’s counsel. Moreover, through his representation in the
`
`related matter, Petitioner has developed a particular relationship with Mr. Kessel
`
`such that Petitioner desires to continue the relationship with Mr. Kessel for the
`
`purpose of this proceeding.
`
`1. Affidavit of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is accompanied by a Declaration
`
`by Mr. Kessel as required by the Order Authorizing Motion for Pro Hac Vice
`
`mailed September 30, 2015.
`
`

`
`Proceeding No.: CBM2015-00181
`Patent No. 7,676,411
`
`Accordingly, TradeStation Group, Inc. and TradeStation Securities, Inc.
`
`submit that there is good cause under 37 C.F.R. § 42.10(c) for the Board to
`
`recognize Mr. Kessel as counsel pro hac vice during this proceeding.
`
`Date:
`
`Respectfully submitted,
`
`Robert E. Sokohi, Reg. No. 36,013
`Attorney for Petitioners
`
`STERNE, KESSLER, GOLDSTEIN & FOX P.L.L.C.
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`Telephone: (202) 371-2600
`
`3
`
`

`
`Proceeding No.: CBM2015-00181
`Patent No. 7,676,411
`
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing
`
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`
`ADMISSION UNDER 37 C.F.R. § 42.10(c) was served electronically via e-mail
`
`on April 15, 2016, in its entirety on the following counsel of record for Patent
`
`Owner:
`
`Erika H. Amer (Lead Counsel)
`Joshua L. Goldberg (Back-up Counsel)
`Kevin D. Rodkey (Back-up Counsel)
`Rachel L. Emsley (Back-up Counsel)
`FINNEGAN, HENDERSON, FARABOW, GARRETT & DUNNER, LLP
`erika. amer(finnegan. corn
`jpjiva.goldberg(2ifinnegan. corn
`kevin.rodkey(finnegan. corn
`rachel. ems1ey(’(cid:228)finnegan. corn
`trading-tech-CBM(2finnegan.com
`
`Steven F. Borsand (Back-up Counsel)
`Trading Technologies International, Inc.
`tt-patent-cbrntradingtechnologies . corn
`
`S R E, KESSLER, GOLDSTEIN & Fox P.L.L.C.
`
`R bert Sokohl (Reg. No. 36,013)
`Attorney for Petitioners
`
`2797738_i .DOC
`
`Date: April 15, 2016
`
`1100 New York Avenue, N.W.
`Washington, D.C. 20005-3934
`(202) 371-2600

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