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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
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`SAMSUNG ELECTRONICS CO. LTD.; SAMSUNG ELECTRONICS AMERICA,
`INC.; AND SAMSUNG AUSTIN SEMICONDUCTOR, LLC;
`PETITIONER
`
`V.
`
`REMBRANDT WIRELESS TECHNOLOGIES, LP
`PATENT OWNER
`___________
`
`Case IPR2014-00518
`Patent 8,023,580
`
`
`Before JAMESON LEE, HOWARD B. BLANKENSHIP, and JUSTIN BUSCH,
`Administrative Patent Judges.
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`
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`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`BRIAN P. BIDDINGER
`
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`Pursuant to Rule 42.10(c), and as authorized in the Board’s Notice of Filing
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`Date Accorded to Petition and Time for Filing Patent Owner Preliminary Response
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`(Paper 3), Petitioners Samsung Electronics Co., Ltd., Samsung Electronics America,
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`Inc., and Samsung Austin Semiconductor, LLC (collectively “Samsung”) respectfully
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`request pro hac vice admission of Brian P. Biddinger as counsel in this proceeding.
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`I. Time for Filing
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`This Motion is timely because it is being filed no sooner than twenty one (21)
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`days after service of the Petition in this proceeding, which occurred on March 20,
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`2014.
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`II. Statement of Facts
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`The following statement of facts demonstrates that there is good cause for the
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`Board to recognize Brian P. Biddinger as counsel pro hac vice in this proceeding. Mr.
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`Biddinger is an experienced litigation attorney and has an established familiarity with
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`the subject matter at issue in this proceeding. Mr. Biddinger has been practicing law
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`since 2003 and has extensive experience litigating patent infringement cases in many
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`different District Courts across the country. Among his experience in patent litigation
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`matters, Mr. Biddinger has been counsel in multiple trials, Markman hearings, patent
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`summary judgment proceedings, and other patent-related hearings and pleadings
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`concerning, inter alia, patent validity and infringement issues. Mr. Biddinger has also
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`been recognized as a leading patent litigation attorney, including as a New York Super
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`Lawyer (2013-2014) and a New York Super Lawyers Rising Star (2011-2012).
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`Mr. Biddinger is familiar with U.S. Patent No. 8,023,580 (“the ‘580 Patent”)
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`and the issues involved in this case. Mr. Biddinger has been representing Petitioners
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`Samsung against Patent Owner Rembrandt Wireless Technologies, LP (“Rembrandt”)
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`as counsel in litigation related to the ’580 Patent since 2014, and has been actively
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`involved as counsel for Samsung since 2013. As counsel in the related litigation, Mr.
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`Biddinger has, among other things, been heavily involved with advancing
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`noninfringement and invalidity positions against Rembrandt’s patents. Accordingly,
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`Samsung prefers that Mr. Biddinger continue as counsel in this IPR proceeding;
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`further, Rembrandt does not oppose Mr. Biddinger’s admission pro hac vice.
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`III. Declaration of Brian P. Biddinger
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`As directed by the Board, this Motion is also accompanied by the Declaration
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`of Brian P. Biddinger in Support of Motion for Pro Hac Vice Admission attesting to
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`the requirements laid out in the Board’s Order Authorizing Motion for Pro Hac Vice
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`Admission in Case IPR2013-00639 (Paper 7).
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`For the foregoing reasons as well as the reasons contained in the attached
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`declaration, Samsung respectfully requests admission of Brian P. Biddinger as counsel
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`pro hac vice.
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`Respectfully submitted,
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`By: /J. Steven Baughman /
`J. Steven Baughman (Lead Counsel)
`Reg. No. 47,414
`ROPES & GRAY LLP
`One Metro Center, 700 12th St., Ste. 900
`Washington, DC 20005-3948
`P: 202-508-4606 / F: 202-383-8371
`steven.baughman@ropesgray.com
`
`Daniel G. Cardy (Backup Counsel)
`Registration No. 66,537
`DICKSTEIN SHAPIRO LLP
`1825 Eye Street NW
`Washington, DC 20006
`P: 202-420-3033
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`
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`3
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`Dated: March 25, 2015
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`
`Gabrielle E. Higgins (Backup Counsel)
`Reg. No. 38,916
`ROPES & GRAY LLP
`1900 University Avenue, Ste. 600
`East Palo Alto, CA 94303
`P: 650-617-4000 /F: 650-617-4090
`gabrielle.higgins@ropesgray.com
`
`
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`
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`Mailing address for all PTAB correspondence: ROPES & GRAY LLP
`IPRM – Floor 43, Prudential Tower, 800 Boylston Street, Boston, MA 02199-3600
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`Attorneys for Petitioners Samsung Electronics Co., Ltd., Samsung Electronics America, Inc., and
`Samsung Austin Semiconductor, LLC
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_________________
`
`SAMSUNG ELECTRONICS CO. LTD.; SAMSUNG ELECTRONICS AMERICA,
`INC.; AND SAMSUNG AUSTIN SEMICONDUCTOR, LLC;
`PETITIONER
`
`V.
`
`REMBRANDT WIRELESS TECHNOLOGIES, LP
`PATENT OWNER
`___________
`
`Case IPR2014-00518
`Patent 8,023,580
`
`
`Before JAMESON LEE, HOWARD B. BLANKENSHIP, and JUSTIN BUSCH,
`Administrative Patent Judges.
`
`
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`DECLARATION OF BRIAN P. BIDDINGER
`IN SUPPORT OF MOTION FOR PRO HAC VICE ADMISSION
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`I, Brian P. Biddinger, being duly sworn and upon oath, hereby attest to the
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`following:
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`1.
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`2.
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`3.
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`I am a member in good standing of the Bars of New York and California.
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`I have never been suspended or disbarred from practice before any court or
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`administrative body.
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`I have never been denied an application for admission to practice before any
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`court or administrative body.
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`4.
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`5.
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`6.
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`7.
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`No sanction or contempt citation has ever been imposed against me by any
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`court or administrative body.
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`I have read and will comply with the Office Patent Trial Practice Guide and the
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`Board’s Rules of Practice for Trials set forth in 37 C.F.R Part 42.
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`I will be subject to the USPTO Rules of Professional Conduct set forth in 37
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`C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`In the last three (3) years, I have applied to appear pro hac vice before the Office
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`in IPR2014-00209, IPR2014-00212, IPR2014-00407, IPR2014-00408, and
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`IPR2014-01181 also on behalf of Samsung entities. Concurrently with the
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`present motion, I intend to file motions to appear pro hac vice before the Office
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`in IPR2014-00519, IPR2014-00892, IPR2014-00893, IPR2014-00895, and
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`IPR2015-00555 also involving Samsung and Rembrandt.
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`8.
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`I am an experienced litigation attorney having familiarity with the subject
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`matter at issue in this proceeding. I have been practicing law since 2003 and
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`have extensive experience litigating patent infringement cases in many different
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`District Courts across the country, including participation in multiple trials,
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`Markman hearings, patent summary judgment proceedings, and other patent-
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`related hearings and pleadings concerning, inter alia, patent validity and/or
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`infringement. I have received professional recognition in the field as a leading
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`patent litigation attorney, including as a New York Super Lawyer (2013-2014)
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`and a New York Super Lawyers Rising Star (2011-2012). I am familiar with
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`
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`2
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`
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`U.S. Patent No. 8,023,580 ("the '580 Patent") and the issues involved in this
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`case. I have represented Samsung against Rembrandt as counsel in litigation
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`related to the '580 Patent since 2014 and have been actively involved as counsel
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`for Samsung since 2013. As counsel in the related litigation, I have, among
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`other things, been heavily involved with advancing noninfringement and
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`invalidity positions against the '580 Patent.
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`I declare under penalty of perjury that the foregoing is true and correct.
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`Executed this 25'h day of March, 2015, in New York, NY.
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`3
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`CERTIFICATE OF SERVICE
`
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`The undersigned certifies that a copy of UNOPPOSED MOTION FOR PRO
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`HAC VICE ADMISSION OF BRIAN P. BIDDINGER and DECLARATION OF
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`BRIAN P. BIDDINGER IN SUPPORT OF MOTION FOR PRO HAC VICE
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`ADMISSION has been served in its entirety by causing the aforementioned
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`document to be electronically mailed, pursuant to the parties’ agreement, to the
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`following attorneys of record for the Patent Owner listed below:
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`Thomas Engellenner (engellet@pepperlaw.com)
`Reza Mollaaghababa (mollaagr@pepperlaw.com)
`Lana Gladstein (gladstel@pepperlaw.com)
`Pepper Hamilton LLP
`125 High Street
`19th Floor, High Street Tower
`Boston, MA 02110
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`Respectfully submitted,
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`/Carolyn L. Redding/
`Carolyn L. Redding
`ROPES & GRAY LLP
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`Dated: March 25, 2015
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