UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICROSTRATEGY, INC.
`
`Petitioner,
`
`Patent of ZILLOW, INC.
`Patent Owner.
`
`Case IPR 2013-00034
`
`Patent No. 7,970,674
`
`
`
`MOTION FOR PRO HAC VICE ADMISSION
`
`UNDER 37 C.F.R. § 42.10
`
`56920-8901 .USOO/LEGAL25353 074.1
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICROSTRATEGY, INC.
`
`Petitioner,
`
`Patent of ZILLOW, INC.
`Patent Owner.
`
`Case IPR 2013-00034
`
`Patent No. 7,970,674
`
`
`
`MOTION FOR PRO HAC VICE ADMISSION
`
`UNDER 37 C.F.R. § 42.10
`
`56920-8901 .USOO/LEGAL25353 074.1
`
`
`
`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 Notice
`
`for Setting the Time Period for Filing Patent Owner Preliminary Response mailed on
`
`November 19, 2012.
`
`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 involved in the litigation. Accordingly, protective orders in the litigation do
`
`not apply to Mr. Al-Salam.
`
`Mr. Al-Salam has, however, advised Zillow on various patent issues and has
`
`appeared as lead counsel for Zillow in multiple patent cases, including:
`
`1. Smarter Agent v Boopsz'e, et al., No. 1:10-cv-00245-JJF-LPS (D. Del.)
`
`2. Trafi’ic Information v. Bank ofAmerica, et al. , No. 2:11-cv-00343-MHS-CMC
`(E.D. Tex.)
`
`-2-
`
`56920-8901 .USOO/LEGAL25353074.1
`
`
`
`3.
`
`IZZ Technology v. Microsoft, et al., No. 3:11-cv—01103-AC (D. Or.)
`
`4. Earthcomber v. Zillow, No. 1:12-cv-OO394-JHL (ND. 111.)
`
`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 (E.D. 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.
`
`3.
`
`Affidavit or Declaration of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is accompanied by an Affidavit of Mr.
`
`Ramsey M. Al-Salam as required by the Order Authorizing Motion for Pro Hac Vice
`
`entered November 19, 2012.
`
`
`
`
`Steven D Lawrenz
`
`Registration No. 37,376
`Lead Counsel for Patent Owner
`
`56920—8901.USOO/LEGAL25353074. l
`
`
`
`AFFIDAVIT OF MR. RAMSEY M. AL-SALAM IN SUPPORT OF
`
`MOTION FOR PRO HAC VICE ADMISSION
`
`I, 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
`
`c. 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
`
`administrative body denied;
`
`4.
`
`No sanction or contempt citation has been imposed against me by any 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 C.F.R.;
`
`56920-8901.USOO/LEGAL25353074. 1
`
`
`
`6.
`
`I will be subject to the USPTO Code of Professional Responsibility set forth in 37
`
`C.F.R. §§ 10.20 et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a);
`
`7.
`
`I have not applied to appear pro hac vice before the Office in any other proceeding
`
`in the last three (3) years; 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 hereto as
`
`Exhibit A.
`
`
`
`Seattle, WA 98101-3099
`Telephone: (206) 359-6385
`Fax: (206) 359—7585
`
`Sworn to
`this I' 6/
`
`d subscrggjd before me,
`day of M471,& 9(D/j;~
`
`Mad/CW3 -~
`Notary Pub ic ‘
`
`"
`
`dfi/
`
`My Commission Expires: (9/40 filo/6%“,3 «00,390
`
`5555.5
`
`56920-8901.USOO/LEGAL253S3074.1
`
`
`
`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. Al-Salam in Support of Motion
`
`for Pro Hac Vice Admission has been served Via Express Mail on December 17, 2012
`
`upon the following:
`
`W. Karl Renner, Lead Counsel
`Fish & Richardson P.C.
`
`P. O. Box 1022.
`
`Minneapolis, MN 55440—1022
`
`Thomas A. Rozylowicz, Back-Up Counsel
`Fish & Richardson P.C.
`
`P. O. Box 1022.
`
`Minneapolis, MN 55440—1022
`
` Sandy Reism
`
`Paralegal
`Perkins Coie LLP
`
`56920-8901.USOO/LEGAL25353074.1
`
`
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