`IPR2014-00473
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
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`INTEL CORPORATION
`Petitioner
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`v.
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`ZOND, LLC
`Patent Owner
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`U.S. Patent No. 7,811,421
`
`_____________________
`
`Inter Partes Review Case No. 2014-00473
`_____________________
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`PATENT OWNER'S MOTION FOR COUNSEL TO
`WITHDRAW FROM THE PROCEEDING AND PERMIT
`SUBSTITUTION OF COUNSEL
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`Patent No. 7,811,421
`IPR2014-00473
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`STATEMENT OF PRECISE RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10, Patent Owner Zond, LLC ("Zond")
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`I.
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`respectfully requests that the Patent Trial and Appeal Board ("the Board")
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`authorize withdrawal of its current counsel, Dr. David C. Radulescu and Dr. Kurt
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`Rauschenbach, and substitution of new counsel Dr. Gregory J. Gonsalves and
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`Bruce J. Barker.
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`II.
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`STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO AUTHORIZE WITHDRAWAL OF COUNSEL
`Dr. David C. Radulescu and Dr. Kurt Rauschenbach were appointed by
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`Zond as its attorneys for the above-captioned inter partes review. Patent Owner
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`Zond now requests that current designated counsel be allowed to withdraw from
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`the present proceeding, and that new counsel listed below be substituted to
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`represent Zond in this proceeding.
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`Lead Counsel:
`
`Bruce Barker
`Reg. No. 33,291
`Chao Hadidi Stark & Barker LLP
`176 East Main Street, Suite 6
`Westborough, MA 01581
`(508) 366-3800
`bbarker@chsblaw.com
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`1
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`Patent No. 7,811,421
`IPR2014-00473
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`Back-up Counsel:
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`Dr. Gregory J. Gonsalves
`Reg. No. 43,639
`2216 Beacon Lane
`Falls Church, Virginia 22043
`(571) 419-7252
`gonsalves@gonsalveslawfirm.com
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`Mr. Barker meets the requirements of 37 C.F.R. § 42.10(c) as lead counsel and is a
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`registered practitioner. In addition Mr. Barker and Dr. Gonsalves have read and
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`intend to comply with the Office Patent Trial Practice Guide and the Board's Rules
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`of Practice for Trials, as set forth in Part 42 of the C.F.R.
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`
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`Counsel for Petitioner has no objections to appointment of Mr. Barker as
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`new lead counsel.
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`Accordingly, Patent Owner Zond respectfully requests that the Board grant
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`its motion to authorize withdrawal of counsel. Also filed concurrently with this
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`motion is an amended Mandatory Notice and new Power of Attorney submission
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`reflecting the new counsel representing Zond.
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`
`
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`Date: April 21, 2014
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`Respectfully submitted,
`
`/David C. Radulescu/
`David C. Radulescu
`Registration No. 36,250
`
`
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`2
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`Patent No. 7,811,421
`IPR2014-00473
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing Patent
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`Owner’s Motion For Counsel To Withdraw From The Proceeding and Permit
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`Substitution Of Counsel and the associated Power of Attorney documents were
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`served via email on April 21, 2014, on the attorneys for the Petitioner:
`
`Richard Goldenberg, Reg. No. 38,895
`Yung-Hoon Ha, Reg. No. 56,368
`Wilmer Cutler Pickering Hale and Dorr LLP
`1875 Pennsylvania Ave., NW
`Washington, DC 20006
`Tel: (202) 663-6000
`Email: Richard.Goldenberg@wilmerhale.com
` Yung-Hoon.Ha@wilmerhale.com
`
`
`
`/David C. Radulescu/
`David C. Radulescu
`Registration No. 36,250
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`3
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