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`____________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`____________
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`TOYOTA MOTOR CORPORATION
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`Petitioner
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`v.
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`AMERICAN VEHICULAR SCIENCES LLC
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`Patent Owner
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`____________
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`Case IPR2013-00417
`Patent 8,036,788
`____________
`
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`MOTION FOR PRO HAC VICE ADMISSION
`OF THOMAS R. MAKIN PURSUANT TO 37 C.F.R. § 42.10(c)
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`
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`Pursuant to instructions from the Trial Paralegal assigned to this trial,
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`Petitioner respectfully requests the pro hac vice admission of Thomas R. Makin as
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`backup counsel for Petitioner in the current proceeding.
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`1.
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`Time for Filing
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`Pursuant to instructions Petitioner received on July 17, 2013 from the Trial
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`Paralegal assigned to this trial, this motion is filed within five business days.
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`2.
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`Content of Motion
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`a.
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`Statement of Facts
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`Pursuant to the Representative Order, the following statement of facts shows
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`good cause for the Board to recognize Mr. Makin pro hac vice during the current
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`proceeding.
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`Mr. Makin is a litigation attorney experienced in patent cases, and is admitted to
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`practice law in New York, and in the United States District Court for the Eastern
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`District of New York, the United States District Court for the Southern District of
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`New York, and the United States Court of Appeals for the Federal Circuit.
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`Mr. Makin has an established familiarity with the subject matter at issue in the
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`proceeding, having represented Petitioner as a defendant in the related proceeding
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`American Vehicular Sciences LLC v. Toyota Motor Corp. et al., No. 6:12-CV-405 (E.D.
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`Tex.). In this related proceeding, Patent Owner has asserted U.S. Patent No.
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`8,036,788 against Petitioner. Mr. Makin’s experience, representing Petitioner in the
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`2
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`related proceeding over the same patent against the same Patent Owner, provides him
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`with an established familiarity with the subject matter at issue in the current
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`proceeding.
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`
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`Petitioner respectfully submits that there is good cause for the Board to
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`recognize Mr. Makin pro hac vice during the current proceeding.
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`b. Declaration
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`
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`Pursuant to the Representative Order, a declaration of Thomas R. Makin is
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`submitted as Exhibit 1009 to this motion.
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`Dated: July 18, 2013
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`A. Antony Pfeffer
`Reg. No. 43,857
`
`A. Antony Pfeffer
`Lead Counsel for Petitioner
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Tel: 212-425-7200
`Fax. 212-425-5288
`Email: apfeffer@kenyon.com
`
`Thomas R. Makin (pro hac vice requested)
`Back-Up Counsel for Petitioner
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Tel: 212-425-7200
`Fax.212-425-5288
`Email: tmakin@kenyon.com
`
`3
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`
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`CERTIFICATE OF SERVICE
`The undersigned hereby confirms that the foregoing Motion for Pro Hac Vice
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`Admission of Thomas R. Makin Pursuant to 37 C.F.R. § 42.10(c) was served on July 18,
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`2013, via Express Mail upon the following:
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`Brian Roffe, Esq.
`8170 McCormick Boulevard, Suite 223
`Skokie, IL 60076-2914
`
`Farshad Farjami
`26522 La Alameda Ave., Suite 360
`Mission Viejo, CA 92691
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`
`
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`Courtesy copy to:
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`
`Amir Alavi
`AHMAD, ZAVITSANOS, ANAIPAKOS, ALAVI & MENSING, P.C.
`1221 McKinney Street, Suite 3460
`Houston, TX 77010
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`Dated: July 18, 2013
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`/A. Antony Pfeffer/
`A. Antony Pfeffer (Reg. No. 43,857)
`Kenyon & Kenyon LLP
`One Broadway
`New York, NY 10004
`Tel: 212-425-7200
`Fax: 212-425-5288
`
`
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