Paper No. 11
`Date Filed: March 29, 2013
`
`Filed on behalf of: CHI MEI INNOLUX CORPORATION
`
`By: Scott A. McKeown
`CPDocketMcKeown@oblon.com
`(703) 412-6297
`_____________________________
`Gregory S. Cordrey
`gxc@jmbm.com
`(949) 623-7236
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CHI MEI INNOLUX CORPORATION
`Petitioner,
`v.
`SEMICONDUCTOR ENERGY LABORATORY, CO., LTD.
`Patent Owner.
`
`Case IPR2013-00038
`U.S. Patent 7,956,978
`
`PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF STANLEY M. GIBSON PURSUANT TO 37 C.F.R. §42.10
`
`
`
`1
`
`
`Date Filed: March 29, 2013
`
`Filed on behalf of: CHI MEI INNOLUX CORPORATION
`
`By: Scott A. McKeown
`CPDocketMcKeown@oblon.com
`(703) 412-6297
`_____________________________
`Gregory S. Cordrey
`gxc@jmbm.com
`(949) 623-7236
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CHI MEI INNOLUX CORPORATION
`Petitioner,
`v.
`SEMICONDUCTOR ENERGY LABORATORY, CO., LTD.
`Patent Owner.
`
`Case IPR2013-00038
`U.S. Patent 7,956,978
`
`PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF STANLEY M. GIBSON PURSUANT TO 37 C.F.R. §42.10
`
`
`
`1
`
`
`
`
`
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`I.
`
`RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. §42.10 and the Board’s “Order Authorizing
`
`Motion for Pro Hac Vice Admission – 37 C.F.R. §42.10,” entered on November 8,
`
`2012, Petitioner Chi Mei Innolux Corporation (now known as Innolux Corporation)
`
`requests that the Board admit Stanley M. Gibson pro hac vice in this proceeding.
`
`II.
`
`STATEMENT OF FACTS
`
`Pursuant to 37 C.F.R. §42.10(c), the Board
`
`may recognize counsel pro hac vice during a proceeding
`upon a showing of good cause, subject to the condition
`that lead counsel be a registered practitioner and to any
`other conditions as the Board may impose. For example,
`where the lead counsel is a registered practitioner, a
`motion to appear pro hac vice by counsel who is not a
`registered practitioner may be granted upon showing that
`counsel is an experienced litigating attorney and has an
`established familiarity with the subject matter at issue in
`the proceeding.
`
`37 C.F.R. §42.10(c). The facts, supported by the attached Declaration of Stanley M.
`Gibson in Support of Motion for Admission Pro Hac Vice (“Gibson Decl.”),
`establish good cause to admit Mr. Gibson pro hac vice in this proceeding.
`
`1. Lead counsel Scott A. McKeown is a registered practitioner
`and is experienced in inter partes proceedings in the USPTO.
`
`2. Backup counsel Gregory S. Cordrey is a registered practitioner
`and is experienced in inter partes proceedings in the USPTO.
`
`3. Stanley M. Gibson is an experienced litigation attorney.
`Mr. Gibson has been a litigation attorney for more than 20 years. (Gibson
`2
`
`
`
`
`
`
`
`Decl. ¶ 1.) Mr. Gibson has been litigating patent cases for approximately
`twelve of those years. (Id. ¶ 2.) Mr. Gibson is a member in good standing
`of the California State Bar, with no suspensions or disbarments from
`practice, nor any application for admission to practice denied, nor any
`sanctions or contempt citations, and is admitted to practice in the United
`States Court of Appeals for the Federal Circuit, United States Court of
`Appeals for the Ninth Circuit, and the United States District Courts for the
`Southern, Central and Northern Districts of California. (Id. ¶¶ 3-6.)
`
`4. Mr. Gibson has familiarity with the subject matter at issue
`in this proceeding based on his work as lead counsel in the pending district
`court case Semiconductor Energy Laboratory Co., Ltd. v. Chi Mei Innolux
`Corp., et al., SACV12-0021-JST (C.D. Cal.), which involves the same
`patent at issue in this proceeding. (Id. ¶ 7.) Mr. Gibson has been actively
`involved in all aspects of the pending district court case, including the issue
`of validity of the patents-in-suit. (Id. ¶¶ 7-8.)
`
`5. Mr. Gibson has read and will comply with the Office Patent
`Trial Practice Guide and the Board’s Rules for Practice for Trials set forth
`in part 42 of the C.F.R, and he agrees to be subject to the USPTO Code of
`Professional Responsibility set forth in 37 C.F.R. §§10.20 et seq., and to
`disciplinary jurisdiction under 37 C.F.R. §11.19(a). (Id. ¶¶ 9-10.) Mr.
`Gibson has not applied to appear pro hac vice in any other proceedings before
`the Office in the last three (3) years. (Id. ¶ 11.)
`
`6. Patent Owner SEL has confirmed via email correspondence
`with lead counsel, Scott McKeown (March 29, 2013), that this Motion will
`not be opposed.
`
`
`
`
`3
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`
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`I I I . A N A L Y S I S
`
`The facts contained in the Statement of Facts above, and contained in
`
`the Gibson Declaration, establish that there is good cause to admit Mr. Gibson
`
`pro hac vice in this proceeding under 37 C.F.R. §42.10. Lead counsel is a registered
`
`practitioner, Mr. Gibson is an experienced litigation attorney, and Mr. Gibson has
`
`an established familiarity with the subject matter at issue in the proceeding.
`
`I V . CONCLUSION
`
`For the foregoing reasons, Petitioner respectfully request that the
`Board admit Stanley M. Gibson pro hac vice in this proceeding.
`
`Respectfully submitted,
`
` / S c o t t A . M c K e o w n /
`
`Scott A. McKeown (Reg. No. 42,866)
`Lead Counsel for Petitioner
`Oblon, Spivak, McClelland, Maier &
`Neustadt, LLP
`1940 Duke Street
`Alexandria, VA 22314
`Tel: (703) 412-6297
`Fax: (703) 413-2220
`CPDocketMcKeown@oblon.com
`
`
`
`Gregory S. Cordrey (Reg. No. 190,144)
`Back-up Counsel for Petitioner
`Jeffer Mangels Butler & Mitchell LLP
`3 Park Plaza, Suite 1100
`Irvine, CA 92614
`Tel: (949) 623-7236
`Fax: (888) 712-3345
`gxc@jmbm.com
`
`Dated: March 29, 2013
`
`
`
`
`4
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`
`
`
`
`
`
`Filed on behalf of: CHI MEI INNOLUX CORPORATION
`By: Scott A. McKeown
`CPDocketMcKeown@oblon.com
`(703) 412-6297
`_____________________________
`Gregory S. Cordrey
`gxc@jmbm.com
`(949) 623-7236
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CHI MEI INNOLUX CORPORATION
`Petitioner,
`v.
`SEMICONDUCTOR ENERGY LABORATORY, CO., LTD.
`Patent Owner.
`
`Case IPR2013-00038
`U.S. Patent 7,956,978
`
`DECLARATION OF STANLEY M. GIBSON IN
`SUPPORT OF PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF STANLEY M. GIBSON PURSUANT TO 37 C.F.R. §42.10
`
`
`
`5
`
`
`
`
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`I, Stanley M. Gibson, declare as follows:
`
`1.
`years of experience.
`
`I am an experienced litigation attorney with more than twenty (20)
`
`2.
`
`I have been litigating patent cases for approximately twelve (12)
`
`years.
`
`3.
`I am a member in good standing of the California State Bar and am
`admitted to practice in the United States Court of Appeals for the Federal Circuit, United
`States Court of Appeals for the Ninth Circuit, and the United States District Courts for the
`Southern, Central and Northern Districts of California.
`
`4.
`I have never been suspended or disbarred from practice before any court
`or administrative body.
`
`5.
`I have never had an application for admission to practice before any court
`or administrative body denied.
`
`6.
`I have had no sanctions or contempt citations imposed against me by any
`court or administrative body.
`
`7.
`
`I am familiar with the subject matter at issue in this proceeding, including
`
`the patent-at-issue. I am lead counsel in the pending district court case Semiconductor Energy
`
`Laboratory Co., Ltd. v. Chi Mei Innolux Corp., et al., SACV12-0021-JST (C.D. Cal.), which
`
`involves the same patent at issue in this proceeding.
`
`8.
`I am actively involved in all aspects of the pending district court case,
`including the issue of validity of the patents-in-suit, which include the patent at issue in this
`proceeding.
`
`9.
`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.
`
`6
`
`
`
`
`
`
`10.
`I agree to be subject to the USPTO Code of Professional Responsibility set
`forth in 37 C.F.R. §§10.20 et seq., and to disciplinary jurisdiction under 37 C.F.R. §11.19(a).
`
`11.
`I have not applied to appear pro hac vice in any proceeding before the
`Office in the last three (3) years.
`
`12.
`
`I hereby declare that all statements made herein of my own knowledge are
`
`true and that all statements made on information and belief are believed to be true; and further
`
`that these statements are made with the knowledge that willful false statements and the like so
`
`made are punishable by fine or imprisonment, or both, under Section 1001 of Title 18 of the
`
`United States Code.
`
`Dated: March 27, 2013
`
`
`
`
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`
`
`
`
`By:
`
`/ Stanley M. Gibson /
`Stanley M. Gibson
`
`7
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`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`CHI MEI INNOLUX CORPORATION
`Petitioner,
`v.
`SEMICONDUCTOR ENERGY LABORATORY, CO., LTD.
`Patent Owner.
`
`Case IPR2013-00038
`U.S. Patent 7,956,978
`
`CERTIFICATE OF SERVICE
`________________
`I hereby certify that PETITIONER’S MOTION FOR ADMISSION PRO HAC
`
`VICE OF STANLEY M. GIBSON PURSUANT TO 37 C.F.R. §42.10 and
`
`attached DECLARATION OF STANLEY M. GIBSON IN SUPPORT OF
`
`PATENT OWNER’S MOTION FOR ADMISSION PRO HAC VICE OF
`
`STANLEY M. GIBSON PURSUANT TO 37 C.F.R. §42.10 in connection with
`
`Inter Partes Review Case IPR2013-00038 was served on this 29th day of March
`
`2013 by Electronic Mail and Express Mail to Robinson Intellectual Property Law
`
`Office, P.C., Counsel
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`for Patent Owner,
`
`at
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`[erobinson@riplo.com;
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`sflood@riplo.com], having a postal address at:
`
`8
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`
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`Robinson Intellectual Property Law Office, P.C
`3975 Fair Ridge Drive
`Suite 20 North
`Fairfax, VA 22030
`
`Dated: March 29, 2013
`
`/ S co t t A . M c K eo w n /
`Scott A. McKeown (Reg. No. 42,866)
`
`9
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