`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`BROSE NORTH AMERICA, INC.
`and
`BROSE FAHRZEUGTEILE GMBH & CO.
`Petitioners
`
`v.
`
`UUSI, LLC
`Patent Owner
`
`
`
`
`Case Number: IPR2014-00416
`Patent No. 8,217,612
`
`
`
`
`MOTION FOR PRO HAC VICE ADMISSION UNDER 37 C.F.R. § 42.10
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark
`Office P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`1
`
`
`
`Petitioners respectfully request that the Board recognize Mr. Luke L.
`
`Dauchot as counsel pro hac vice during this proceeding under 37 C.F.R. § 42.10.
`
`Petitioners seek Mr. Dauchot’s assistance because of his experience assisting
`
`Petitioner Brose North America, Inc. on patent-related matters and his
`
`experience on the substantive and technical issues involved in this proceeding.
`
`Petitioners note that their lead and back-up counsel, Craig D. Leavell (No. 48,505)
`
`and Alyse Wu (No. 68,926) are registered practitioners.
`
`I.
`
`STATEMENT OF FACTS
`
`Mr. Dauchot is an experienced patent litigation attorney, with over 20
`
`years of experience in discovery, jury and bench trials, Markman hearings, and
`
`appellate oral arguments in patent infringement matters. Mr. Dauchot is a
`
`member of the American Bar Association (Intellectual Property Law and
`
`Litigation Sections), American
`
`Intellectual Property Law Association,
`
`International Bar Association, Los Angeles Intellectual Property Law
`
`Association, and Judge Paul R. Michel Intellectual Property American Inn of
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`Court (Executive Committee member). Mr. Dauchot’s biography, including a
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`list of representative cases, distinctions, publications, and professional
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`activities, is attached as Exhibit A.
`
`Mr. Dauchot was granted pro hac vice admission by the Office in
`
`multiple separate proceedings:
`
`
`
`2
`
`
`
`• NuVasive, Inc. v. Warsaw Orthopedic, Inc., IPR2013-00206 (granted on May
`15, 2013, Paper 10);
`• NuVasive, Inc. v. Warsaw Orthopedic, Inc., IPR2013-00208 (granted on May
`15, 2013, Paper 10);
`• NuVasive, Inc. v. Warsaw Orthopedic, Inc., IPR2013-00395 (granted on
`February 25, 2014, Paper 19); and
`• NuVasive, Inc. v. Warsaw Orthopedic, Inc., IPR2013-00396 (granted on
`February 25, 2014, Paper 19).
`
`Furthermore, U.S. Patent No. 8,217,612 is currently asserted in a
`
`co-pending litigation, UUSI, LLC v. Robert Bosch LLC and Brose North America,
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`Inc., No. 2:13-cv-10444 (E.D. Mich) (the “co-pending litigation”). Mr. Dauchot
`
`is lead counsel for Petitioner Brose North America, Inc. in the co-pending
`
`litigation and, as such, has an established familiarity with the subject matter at
`
`issue in this proceeding. Petitioners wish to use Mr. Dauchot as counsel in this
`
`proceeding.
`
`Therefore, there is good cause for the Board to recognize Mr. Dauchot as
`
`counsel pro hac vice during this proceeding.
`
`II. AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
`
`This Motion for Pro Hac Vice Admission is accompanied by an Affidavit
`
`of Mr. Luke L. Dauchot. This affidavit is submitted as Exhibit 1030.
`
`
`
`
`
`3
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`
`
`Date: September 10, 2014
`
`Respectfully submitted,
`
`
`
`
`
`
`
`
`
`/s/ Craig D. Leavell
`Craig D. Leavell (Reg. No. 48505)
`Alyse Wu (Reg. No. 68926)
`KIRKLAND & ELLIS LLP
`300 North LaSalle Street
`Chicago, Illinois 60654
`P: 312.862.2000; F: 312.862.2200
`craig.leavell@kirkland.com
`alyse.wu@kirkland.com
`Attorneys For Petitioners
`
`4
`
`
`
`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of this Motion for Pro Hac Vice
`
`Admission and copy of the Affidavit of Mr. Luke L. Dauchot in Support of
`
`Motion for Pro Hac Vice Admission was served on September 10, 2014 via FedEx
`
`delivery directed to the attorney of record for the patent at the following address:
`
`TAROLLI, SUNDHEIM, COVELL & TUMMINO L.L.P.
`
`1300 East Ninth Street, Suite 1700
`Cleveland, Ohio 44114
`
`A copy was also served via FedEx delivery on:
`
`George D. Moustakas
`Harness, Dickey & Pierce, P.L.C.
`5445 Corporate Drive, Suite 200
`Troy, MI 48098
`
`
`
` /s/ Craig D. Leavell
`Craig D. Leavell
`
`
`
`
`
`4
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`
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