Paper No.
`
`Date Filed: December 23, 2013
`
`Filed on behalf of: MPHJ Technology Investments, LLC
`
`By: Scott A. Horstemeyer
`
`scott.h0rstemeyer@thomashorstemeyer.corn
`
`(770) 933-9500
`
`
`
`Vivek Ganti
`
`Vivek.ganti@thomashorstemeyer.com
`
`(770) 933-9500
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`RICOH AMERICAS CORPORATION AND XEROX CORPORATION
`
`Petitioners,
`
`V.
`
`MPHJ TECHNOLOGY INVESTMENTS, LLC
`
`Patent Owner
`
`Case IPR2013 -003 02
`
`US. Patent 7,986,426
`
`
`
`Date Filed: December 23, 2013
`
`Filed on behalf of: MPHJ Technology Investments, LLC
`
`By: Scott A. Horstemeyer
`
`scott.h0rstemeyer@thomashorstemeyer.corn
`
`(770) 933-9500
`
`
`
`Vivek Ganti
`
`Vivek.ganti@thomashorstemeyer.com
`
`(770) 933-9500
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`RICOH AMERICAS CORPORATION AND XEROX CORPORATION
`
`Petitioners,
`
`V.
`
`MPHJ TECHNOLOGY INVESTMENTS, LLC
`
`Patent Owner
`
`Case IPR2013 -003 02
`
`US. Patent 7,986,426
`
`
`
`PATENT OWNER’S MOTION FOR ADMISSION
`
`PRO HAC VICE OF STEVEN G. HILL PURSUANT TO 37 C.F.R. §42.lO
`
`I. RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. §42. 10 and the Notice of Filing Date Accorded, which
`
`authorizes parties to file motions for pro hac vice admission, Patent Owner MPH]
`
`Technology Investments, LLC requests that the Board admit Steven G. Hill 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 Steven G.
`
`Hill (Ex 2001) in Support of Motion for Admission Pro Hac Vice, establish good
`
`cause to admit Mr. Hill pro hac vice in this proceeding.
`
`1. Lead counsel Scott Horstemeyer is a registered practitioner and is
`
`experienced in inter partes proceedings in the USPTO.
`
`
`
`2. Backup counsel Vivek Ganti is a registered practitioner and is experienced
`
`in inter partes proceedings in the USPTO.
`
`3. Steven G. Hill is an experienced litigating attorney. Mr. Hill has been a
`
`litigating attorney for more than 19 years. (Ex 2001. 11 1.) Mr. Hill has been
`
`litigating patent cases for at least 15 of those years. (Id. 11 2.) Mr. Hill is a
`
`member in good standing of the Georgia 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,
`
`the United
`
`States Court of Appeals for the Sixth Circuit, the United States Court of
`
`Appeals for the Tenth Circuit, the United States Court of Appeals for the
`
`Eleventh Circuit and the United States District Courts for the Northern and
`
`Middle Districts of Georgia. (Id. 11 3.)
`
`4. Mr. Hill has familiarity with the subject matter at issue in this proceeding
`
`based on his work as lead counsel in the following district court cases:
`
`0 Project Paperless, LLC v. UAV Communications, Inc. and Bosh Global
`
`Systems, Case No. 3:12-cv-39 filed January 18, 2012 in the US. District
`
`Court for the Eastern District of Virginia.
`
`
`
`0 Project Paperless, LLC v. BlueWave Computing, LLC, et al., Case No.
`
`1:12-cv-00995-SCJ filed March 23, 2012 in the US. District Court for
`
`the Northern District of Georgia.
`
`These cases involved the same patent at issue in this proceeding. (Id. 1111 7-8.)
`
`Mr. Hill has been actively involved in all aspects of these district court
`
`cases, including the issue of validity of the patents-in—suit. (Id. W 7-8.)
`
`5. Mr. Hill 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. §ll.l9(a). (Id. M 9-10.) Mr. Hill has not
`
`applied to appear pro hac vice in any other proceedings before the Office in
`
`the last three (3) years. (Id. 1] 11.)
`
`III. ANALYSIS
`
`The facts contained in the Statement of Facts above, and contained in the
`
`Hill Declaration, establish that there is good cause to admit Mr. Hill pro hac vice in
`
`this proceeding under 37 C.F.R. §42.10. Lead and backup counsel are registered
`
`
`
`practitioners, Mr. Hill is an experienced litigating attorney, and Mr. Hill has an
`
`established familiarity with the subject matter at issue in the proceeding.
`
`IV. CONCLUSION
`
`For the foregoing reasons, Patent Owner MPHJ Technology Investments,
`
`LLC respectfully request that the Board admit Steven G. Hill pro hac vice in this
`
`proceeding.
`
`Respectfully submitted,
`Dated: December 23, 2013
`/Scott A. Horstemeyer/
`
`Scott A. Horstemeyer
`(Reg. No. 27,276)
`Lead Counsel for Patent Owner
`
`Thomas Horstemeyer
`400 Interstate North Pkwy Ste. 1500
`Atlanta, Georgia 30339
`Tel: (770) 933—9500
`Fax: (770) 951-0933
`
`
`
`Filed on Behalf of MPHJ TECHNOLOGY INVESTMENTS, INC
`By:
`Scott A. Horstemeyer (scott.horstemeyer@thomashorstemeyer.corn)
`N. Andrew Crain (andrew.crain@thomashorstemeyer.com)
`Vivek Ganti (Vivek.ganti@thomashorstemeyer.com)
`THOMAS | HORSTEMEYER, LLP
`400 Interstate North Parkway, SE
`Suite 1500
`
`Atlanta, Georgia 30339
`Tel: (770) 933-9500
`Fax: (770) 951—0933
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`RICOH AMERICAS CORPORATION AND XEROX CORPORATION,
`Petitioners
`
`V.
`
`MPHJ TECHNOLOGY INVESTMENTS, LLC,
`Patent Owner
`
`Case IPR20 1 3-003 02
`
`Patent 7,986,426
`
`Before Patrick E. Baker, Trial Paralegal
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned herby certifies that a copy of the foregoing Patent Owner’s
`
`Motion for Admission Pro Hac Vice of Steven G. Hill under 37 C.F.R. § 42.10 was
`
`served on counsel of record on December 23, 2013, and that this document was
`
`filed through the Patent Review Processing System and served electronically via
`
`email.
`
`Michael D. Specht
`STERNE KESSLER GOLDSTEIN FOX
`
`1 100 New York Avenue, NW
`Washington DC. 20005
`mspecht@skgf.com
`
`Jason D. Eisenberg
`STERNE KESSLER GOLDSTEIN FOX
`
`1100 New York Avenue, NW
`Washington DC. 20005
`jeisenbe@skgf.com
`
`THOMAS | HORSTEMEYER, LLP
`
`ScottA. Horstieyer
`
`j
`
`Lead Counsel
`
`Attorney for Patent Owner
`Registration No. 34,183
`
`
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