Paper No.
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`SONY CORPORATION
`Petitioner
`v.
`
`YISSUM RESEARCH DEVELOPMENT COMPANY
`OF THE HEBREW UNIVERSITY OF JERUSALEM
`Patent Owner
`
`Patent No. 7,477,284
`Issue Date: January 13, 2009
`Title: SYSTEM AND METHOD FOR CAPTURING
`AND VIEWING STEREOSCOPIC PANORAMIC IMAGES
`_____________________
`
`Inter Partes Review No. IPR2013-00219
`_________________________________________________________
`
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`MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`SONY CORPORATION
`Petitioner
`v.
`
`YISSUM RESEARCH DEVELOPMENT COMPANY
`OF THE HEBREW UNIVERSITY OF JERUSALEM
`Patent Owner
`
`Patent No. 7,477,284
`Issue Date: January 13, 2009
`Title: SYSTEM AND METHOD FOR CAPTURING
`AND VIEWING STEREOSCOPIC PANORAMIC IMAGES
`_____________________
`
`Inter Partes Review No. IPR2013-00219
`_________________________________________________________
`
`
`MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10
`
`
`
`Motion for Pro Hac Vice Admission
`IPR2013-00219
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`As authorized by the Notice of Filing Date Accorded to Petition (Paper 6 at
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`2), Patent Owner Yissum Research Development Company of the Hebrew
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`University of Jerusalem respectfully moves that the Board recognize Mr. William
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`P. Nelson and Mr. Robert L. Gerrity as counsel pro hac vice during this
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`proceeding. This motion is filed in accordance with the “Order Authorizing
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`Motion for Pro Hac Vice Admission” in case IPR2013-00010. (See Paper 6 at 2.)
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`1. Time for Filing
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`This Motion for Pro Hac Vice Admission is being filed no sooner than twenty
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`one (21) days after service of the petition.
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`2. Statement of Facts Showing Good Cause for Counsel Pro Hac Vice
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`As required by the Order Authorizing Motion for Pro Hac Vice, the
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`following statement of facts shows that there is good cause for the Board to
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`recognize Mr. Nelson and Mr. Gerrity pro hac vice.
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`Mr. Nelson is special counsel at Tensegrity Law Group LLP, is an
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`experienced litigation attorney, and has been involved in numerous litigations
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`involving patent infringement in District Courts across the country. Mr. Nelson is
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`a member of the California bar in good standing and is admitted to practice before
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`the U.S. Court of Appeals for the Federal Circuit; the U.S. District Court for the
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`Northern District of California; the U.S. District Court for the Southern District of
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`R-333907_1
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`2
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`
`
`Motion for Pro Hac Vice Admission
`IPR2013-00219
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`California; and the U.S. District Court for the Eastern District of Texas. He has
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`experience in fact and expert document and deposition discovery, claim
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`construction, Markman hearings, motion practice,
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`jury and bench
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`trials,
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`investigations before the International Trade Commission, and oral arguments in
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`connection with patent infringement litigation matters.
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`Mr. Gerrity is an associate at Tensegrity Law Group LLP, is an experienced
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`litigation attorney, and has been involved in numerous litigations involving patent
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`infringement in District Courts across the country. Mr. Gerrity is a member of the
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`California bar in good standing and is admitted to practice in the U.S. District
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`Court for the Northern District of California; the U.S. District Court for the Central
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`District of California; the U.S. District Court for the Southern District of
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`California; and the U.S. District Court for the Eastern District of Texas. He has
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`experience in fact and expert document and deposition discovery, claim
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`construction, motion practice,
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`jury
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`trials, and
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`investigations before
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`the
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`International Trade Commission in connection with patent infringement litigation
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`matters.
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`Mr. Nelson and Mr. Gerrity have an established familiarity with the subject
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`matter at issue in this proceeding from their participation in co-pending litigation
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`involving the subject patent.
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`R-333907_1
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`3
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`
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`Motion for Pro Hac Vice Admission
`IPR2013-00219
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`Specifically, U.S. Patent No. 7,477,284 is currently asserted against
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`Petitioner Sony Corporation in a co-pending litigation, HumanEyes Technologies
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`Ltd. V. Sony Electronics Inc. et al., No. 1:12-cv-00398-GMS (D.Del.), and was
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`also asserted in the Matter of Certain Cameras and Mobile Devices, Related
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`Software and Firmware, and Components Thereof and Products Containing the
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`Same, Investigation No. 337-TA-842, United States Trade Commission (“the
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`related litigations”). HumanEyes Technologies Ltd. is the exclusive licensee of
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`U.S. Patent No. 7,477,284, and Mr. Nelson and Mr. Gerrity are counsel for
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`HumanEyes Technologies Ltd. in the related litigations.
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`Mr. Nelson and Mr. Gerrity have analyzed prior art references and claims
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`charts in connection with invalidity contentions, have been involved in forming
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`claim construction positions, and conducted document and deposition discovery
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`related to the claimed inventions all of which are relevant to the petition requesting
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`inter partes review of U.S. Patent No. 7,477,284. HumanEyes has expended
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`significant resources in the related litigation with Mr. Nelson and Mr. Gerrity as its
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`counsel, and the Patent Owner wishes to apply Mr. Nelson’s and Mr. Gerrity’s
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`knowledge of the patent by employing them as counsel in this proceeding.
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`Further, Petitioner does not oppose Mr. Nelson or Mr. Gerrity appearing Pro
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`Hac Vice during this proceeding.
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`R-333907_1
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`4
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`
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`Motion for Pro Hac Vice Admission
`IPR2013-00219
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`Therefore, Patent Owner respectfully submits that there is good cause for the
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`Board to recognize Mr. Nelson and Mr. Gerrity as counsel Pro Hac Vice during
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`this proceeding.
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`3. Affidavit or Declaration of Individuals Seeking to Appear
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`This Motion for Pro Hac Vice Admission is accompanied by Affidavits of
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`Mr. William P. Nelson (YRD-1001) and Mr. Robert L. Gerrity (YRD-1002) as
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`required by the Order Authorizing Motion for Pro Hac Vice Admission.
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`Respectfully submitted,
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`By /David L. McCombs/
`David L. McCombs
`Registration No. 32,271
`Lead Counsel for Patent Owner,
`Yissum Research Development
`Company of
`The Hebrew University of Jerusalem
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`
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`R-333907_1
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`5
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`
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`Motion for Pro Hac Vice Admission
`IPR2013-00219
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`Exhibit List
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`Affidavit of Mr. William P. Nelson in Support of Motion for Pro
`Hac Vice Admission
`Affidavit of Mr. Robert L. Gerrity in Support of Motion for Pro
`Hac Vice Admission
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`YRD-1001
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`YRD-1002
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`R-333907_1
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`6
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`SONY CORPORATION
`Petitioner
`v.
`
`YISSUM RESEARCH DEVELOPMENT COMPANY
`OF THE HEBREW UNIVERSITY OF JERUSALEM
`Patent Owner
`___________________
`
`Case IPR2013-00219
`_____________________
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`
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`CERTIFICATE OF SERVICE
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`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that
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`service was made on the Petitioner as detailed below.
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`Date of service June 20, 2013
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`Manner of service Electronic Mail (Sony-HumanEyes@kenyon.com)
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`Documents served MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10
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`Exhibits YRD-1001 & YRD-1002
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`Persons Served Walter Hanley and Michelle Carniaux
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`
`/David L. McCombs/
`David L. McCombs
`Registration No. 32,271
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