`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Paper No. ________
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`MICRO MOTION, INC.
`Petitioner
`v.
`
`INVENSYS SYSTEMS, INC.
`Patent Owner
`
`
`
`Patent No. 7,571,062
`Issue Date: August 4, 2009
`Title: DIGITAL FLOWMETER
`_______________
`
`Inter Partes Review No. IPR2014-00393
`____________________________________________________________
`
`
`
`
`
`Petitioner’s Unopposed Motion For Pro Hac Vice
`Admission Of Kadie M. Jelenchick
`37 C.F.R. § 42.10(c)
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`4817-6969-3468.1
`
`
`
`IPR2014-00393
`Patent 7,571,062
`
`I.
`
`RELIEF REQUESTED
`
`
`
`Petitioner Docket No. 087886-0122
`
`Pursuant to 37 C.F.R. § 42.10(c), Petitioner, Micro Motion, Inc., respectfully
`moves the Board to recognize counsel Kadie M. Jelenchick pro hac vice for
`purposes of the above-captioned inter partes review.
`II. AUTHORIZATION FOR THIS MOTION
`
`This motion was authorized pursuant to the Board's notice according a filing
`date to the petition.
`III. GOOD CAUSE EXISTS TO GRANT THIS MOTION
`Good cause exists to recognize Ms. Jelenchick pro hac vice. The undersigned
`lead counsel, Andrew S. Baluch, is a registered practitioner. As set forth in the
`accompanying Affidavit In Support Of Motion For Pro Hac Vice Admission of
`Kadie M. Jelenchick (Ex. 1067), Ms. Jelenchick is an experienced litigation
`attorney with an established familiarity with the subject matter at issue in this inter
`partes review. (Ex. 1067 at ¶ 10) Ms. Jelenchick is admitted to practice in
`Wisconsin. (Id. ¶ 3) Ms. Jelenchick is a member of the trial team in Invensys
`Systems, Inc. v. Emerson Electric Co. and Micro Motion, USA., No. 6:12-cv-
`00799 (E.D. TX), which involves the same patent and subject matter at issue in this
`proceeding (Id. ¶ 11). Ms. Jelenchick received her J.D. from University of
`Houston Law Center and graduated with a B.S. in Biomedical Engineering from
`University of Rochester.
`Ms. Jelenchick has read and will comply with the Office Patent Trial Practice
`Guide and the Board’s Rules of Practice for Trials (Id. ¶ 7), and further
`
`
`
`4817-6969-3468.1
`
`
`
`Petitioner Docket No. 087886-0122
`
`IPR2014-00393
`Patent 7,571,062
`
`understands that she will be subject to the USPTO Code of Professional
`Responsibility (Id. ¶ 8).
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Date:
`
` September 29, 2014
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Andrew S. Baluch/
`Andrew S. Baluch
`Registration No. 57,503
`Counsel for Petitioner
`
`4817-6969-3468.1
`
`
`
`IPR2014-00393
`Patent 7,571,062
`
`
`Petitioner Docket No. 087886-0122
`
`
`
`
`CERTIFICATE OF SERVICE
`
`
`The undersigned hereby certifies that a copy of the foregoing Petitioner’s
`
`Unopposed Motion For Pro Hac Vice Admission Of Kadie M. Jelenchick, was
`
`served on counsel of record on September 29, 2014, by filing this document
`
`through the Patent Review Processing System as well as delivering a copy via
`
`email to the counsel of record for the Petitioner at the following addresses:
`
`
`
`
`
`
`
`4817-6969-3468.1
`
`jeffrey.johnson@dlapiper.com
`Invensys_Micro_IPR@dlapiper.com
`
`
`
`
`
`
`
`
`
`
`/Nora L. Luersen/
`Nora L. Luersen
`Foley & Lardner LLP
`
`
`
`
`Date: September 29, 2014
`
`
`
`
`
`
`
`
`
`
`
`