UNITED STATES PATENT AND TRADEMARK OFFICE
`________________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`
`INNOLUX CORPORATION
`(formerly CHI MEI INNOLUX CORPORATION)
`
`Petitioner
`
`v.
`
`SEMICONDUCTOR ENERGY
`LABORATORY CO., LTD.
`
`Patent OWNER
`____________
`
`Case IPR2013-00065
`
`Patent 7,923,311
`____________
`
`
`PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF STANLEY M. GIBSON
`PURSUANT TO 37 C.F.R. §42.10
`
`
`
`Mail Stop "PA TENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`________________________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________________
`
`
`INNOLUX CORPORATION
`(formerly CHI MEI INNOLUX CORPORATION)
`
`Petitioner
`
`v.
`
`SEMICONDUCTOR ENERGY
`LABORATORY CO., LTD.
`
`Patent OWNER
`____________
`
`Case IPR2013-00065
`
`Patent 7,923,311
`____________
`
`
`PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF STANLEY M. GIBSON
`PURSUANT TO 37 C.F.R. §42.10
`
`
`
`Mail Stop "PA TENT BOARD"
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`Petitioner’s Motion for Admission
`Pro Hac Vice of Stanley M. Gibson
`Case IPR2013-00065
`Patent 7,923,311
`
`
`
`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 December 5, 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.
`
`
`
`Petitioner’s Motion for Admission
`Pro Hac Vice of Stanley M. Gibson
`Case IPR2013-00065
`Patent 7,923,311
`
`
`
`
`
`
`3. Stanley M. Gibson is an experienced litigation attorney.
`Mr. Gibson has been a litigating attorney for more than 20 years. (Gibson
`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 applied to appear pro hac vice in other proceedings before the
`
`
`
`Petitioner’s Motion for Admission
`Pro Hac Vice of Stanley M. Gibson
`Case IPR2013-00065
`Patent 7,923,311
`
`
`
`
`Office in the last three (3) years as indicated in the attached declaration. (Id.
`¶¶11-12.)
`
`6. Patent Owner Semiconductor Energy Laboratory Co., Ltd.
`has indicated that this Motion will not be opposed.
`
`7. On March 29, 2013, Mr. Gibson applied to appear pro hac
`vice before the Office in Inter Partes Review Cases IPR2013-00028 and
`IPR2013-00038. On April 2, 2013, the Office granted these motions for pro
`hac vice admission. On April 30, 2013, Mr. Gibson applied to appear pro
`hac vice before the Office in Inter Partes Review Cases IPR2013-00066 and
`IPR2013-000368. A decision on these motions for pro hac vice admission
`has not yet been received.
`
`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 are registered
`
`practitioners, Mr. Gibson is an experienced litigation attorney, and Mr. Gibson has
`
`an established familiarity with the subject matter at issue in the proceeding.
`
`
`
`Petitioner’s Motion for Admission
`Pro Hac Vice of Stanley M. Gibson
`Case IPR2013-00065
`Patent 7,923,311
`
`
`
`
`IV. CONCLUSION
`
`For the foregoing reasons, Petitioner respectfully request that the Board
`admit Stanley M. Gibson pro hac vice in this proceeding.
`
`Respectfully submitted,
`
`Dated: May 6, 2013
`
`
`/s/ Scott A. McKeown
`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
`
`
`
`
`Petitioner’s Motion for Admission
`Pro Hac Vice of Stanley M. Gibson
`Case IPR2013-00065
`Patent 7,923,311
`
`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 was served on May
`
`6, to the following at their email addresses indicated below:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Eric Robinson
`erobinson@riplo.com
`
`Sean C. Flood
`sflood@riplo.com
`
`ROBINSON INTELLECTUAL PROPERTY LAW OFFICE, P.C.
`
`
`
`Dated: May 6, 2013
`
`/ s / S co t t A . M c K eo w n
`Scott A. McKeown
`
`
`
`
`
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