`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
` ____________
`
`TOYOTA MOTOR NORTH AMERICA, INC., SUBARU OF AMERICA, INC.,
`AMERICAN HONDA MOTOR CO., INC., NISSAN NORTH AMERICA, INC.,
`FORD MOTOR COMPANY, JAGUAR LAND ROVER NORTH AMERICA,
`LLC, AND VOLVO CARS OF NORTH AMERICA, LLC,
`Petitioner
`
`v.
`
`CRUISE CONTROL TECHNOLOGIES LLC
`Patent Owner
`
`____________
`
`Case No. IPR2014-00281
`Patent No. 6,324,463
` ____________
`
`
`
`
`
`PETITIONER FORD MOTOR COMPANY’S MOTION FOR COUNSEL
`TO WITHDRAW AND PERMIT SUBSTITUTION OF NEW COUNSEL
`
`
`
`
`
`
`
`
`I.
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.10, and as authorized by the Board via e-mail on
`
`December 19, 2014, Petitioner Ford Motor Company (“Ford”) respectfully requests
`
`that the Patent Trial and Appeal Board (“the Board”) authorize withdrawal of its
`
`current counsel, Matthew J. Moore and Michael B. Eisenberg, and substitution of new
`
`counsel Eric A. Buresh and Jason R. Mudd. Mr. Moore should remain listed as back-
`
`up counsel in this petition as counsel for Jaguar Land Rover North America, LLC.
`
`II.
`
`STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO AUTHORIZE WITHDRAWAL OF COUNSEL
`
`Matthew J. Moore and Michael B. Eisenberg were appointed by Ford as its
`
`attorneys for the above-captioned inter partes review. Petitioner Ford now requests
`
`that current designated counsel be allowed to withdraw from the present proceeding,
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`and that new counsel listed below be substituted to represent Ford in this proceeding.
`
`Lead Counsel
`Eric A. Buresh (Reg. No. 50,394)
`eric.buresh@eriseip.com
`
`Back-Up Counsel
`Jason R. Mudd (Reg. No. 57,700)
`jason.mudd@eriseip.com
`
`Postal and Hand-Delivery Address:
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, Kansas 66211
`Telephone: (913) 777-5600
`Fax: (913) 777-5601
`
`Counsel for Ford Motor Company
`
`Postal and Hand-Delivery Address:
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, Kansas 66211
`Telephone: (913) 777-5600
`Fax: (913) 777-5601
`
`Counsel for Ford Motor Company
`
`
`
`
`
`-1-
`
`
`
`
`Mr. Buresh and Mr. Mudd meet the requirements of 37 C.F.R. § 42.10 as lead and
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`back-up counsel and are both registered practitioners. In addition, Mr. Buresh and
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`Mr. Mudd have read and intend to comply with the Office Patent Trial Practice Guide
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`and the Board's Rules of Practice for Trials, as set forth in Part 42 of the C.F.R.
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`
`
`No extensions of time are sought with this Motion and granting this Motion
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`will not cause delay in the proceeding or any prejudice to Patent Owner.
`
`
`
`As required by 37 C.F.R. §42.10(b), an executed Power of Attorney is filed
`
`concurrently. Upon grant of this Motion, Petitioner will promptly file an Updated
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`Mandatory Notice under 37 C.F.R § 42.8(b)(3) and (b)(4) identifying the new counsel.
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`Counsel for Patent Owner was consulted and has no objections to
`
`appointment of Mr. Buresh and Mr. Mudd as new lead and back-up counsel,
`
`respectively.
`
`III. CONCLUSION
`
`Accordingly, Petitioner Ford respectfully requests that the Board grant its
`
`motion to authorize withdrawal of counsel.
`
`
`
`
`
`
`
`
`-2-
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`
`
`Dated: January 5, 2015
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`By: /s/Matthew J. Moore
`Matthew J. Moore
`Reg. No. 42012
`Latham & Watkins LLP
`555 Eleventh St., N.W. Suite 1000
`Washington, DC 20004
`202.637.2278
`202.637.2201 (Fax)
`
`Michael B. Eisenberg
`Reg. No. 50643
`Latham & Watkins LLP
`885 Third Avenue
`New York, NY 10022-4834
`212.906.1655
`212.751.4868 (Fax)
`
`Counsel for Petitioner Ford Motor
`Company
`
`
`
`
`
`
`-3-
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`
`
`The undersigned certifies that a copy of the attached PETITIONER FORD
`
`MOTOR COMPANY’S MOTION FOR COUNSEL TO WITHDRAW AND
`
`PERMIT SUBSTITUTION OF NEW COUNSEL was sent via electronic mail on
`
`January 5, 2015, to the following:
`
`John R. Kasha, Reg. No. 53,100
`Kelly L. Kasha, Reg. No. 47,743
`Kasha Law LLC
`14532 Dufief Mill Rd.
`North Potomac, MD 20878
`(703) 867-1886
`john.kasha@kashalaw.com
`kelly.kasha@kashalaw.com
`
`Counsel of Record for U.S. Patent No. 6,324,463
`
`
`
`
`
`
`
`
`
`By:
`
`/s/Matthew J. Moore
`Matthew J. Moore
`Reg. No. 42012
`Latham & Watkins LLP
`555 Eleventh St., N.W. Suite 1000
`Washington, DC 20004
`202.637.2278
`202.637.2201 (Fax)
`
`
`Counsel for Petitioner Ford Motor Company
`
`
`
`
`
`
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