UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`FORD MOTOR COMPANY, INC.
`Petitioner
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`v.
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`PAICE LLC & THE ABELL FOUNDATION, INC.
`Patent Owner
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`Case IPR2014-00571
`Patent 7,104,347
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`PATENT OWNER PAICE LLC & THE ABELL FOUNDATION, INC.
`MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. § 42.10(c)
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`FORD MOTOR COMPANY, INC.
`Petitioner
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`v.
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`PAICE LLC & THE ABELL FOUNDATION, INC.
`Patent Owner
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`Case IPR2014-00571
`Patent 7,104,347
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`PATENT OWNER PAICE LLC & THE ABELL FOUNDATION, INC.
`MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. § 42.10(c)
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`Proceeding No.: IPR2014-00571
`Attorney Docket: 36351-0011IP1
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`Pursuant to 37 C.F.R. § 42.10(c), the Patent Owner (“Paice LLC & the Abell
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`Foundation, Inc., hereinafter PAICE & ABELL”) respectfully requests that the
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`Board recognize William Peter Guarnieri as counsel pro hac vice in this
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`proceeding. Patent Owner seeks the counsel of William Peter Guarnieri due to his
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`experience in representing PAICE & ABELL in other patent-related matters and
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`particularly due to his familiarity with the substantive and technical issues involved
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`in this proceeding. This motion is authorized by the Notice of Filing Date
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`Accorded to Petition and Time for Filing Patent Owner Preliminary Response that
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`was mailed on April 11, 2014.
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`Statement of Facts
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`Mr. Guarnieri is an attorney whose practice focuses on patent litigation in
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`Federal District Courts and Section 337 proceedings before the International Trade
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`Commission. He has been involved in cases covering a broad range of
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`technologies, including complex software applications, 3D graphics accelerators,
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`portable audio docks, consumer digital cameras, hybrid-electric vehicles, and
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`photonic integrated circuits. Through his practice in such cases, Mr. Guarnieri has
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`gained substantial experience in trials, discovery procedures, depositions,
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`Markman hearings, and briefing pleadings on various aspects of patent law. Mr.
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`Guarnieri received his J.D. from Georgetown University Law Center in 2011,
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`where he was on the Executive Board of the American Criminal Law Review. He
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`Proceeding No.: IPR2014-00571
`Attorney Docket: 36351-0011IP1
`received his B.A. in Computer Science from Duke University in 2004. Prior to
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`practicing law, Mr. Guarnieri was a software consultant/developer for a software
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`company in the DC area. Mr. Guarnieri was involved in developing enterprise
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`software systems for a number of clients, including the U.S. Army’s Army
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`Knowledge Online portal. PAICE & ABELL provides Exhibit A, as evidence, Mr.
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`Guarnieri’s biography.
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`Mr. Guarnieri also has particular experience and familiarity with the
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`substantive and technical issues involved in this inter partes review proceeding.
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`Mr. Guarnieri represents PAICE & ABELL in two related matters: Paice LLC, et.
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`al. v. Hyundai Motor Co., et. al., No. CIV. WDQ-12-0499 (D. Md.) and Paice
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`LLC, et. al. v. Ford Motor Company, No. CIV. WDQ-14-cv-00492 (D. Md.). Both
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`cases are currently pending in the U.S. District Court for the District of Maryland,
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`and both involve U.S. Patent 7,104,347, as well as other patents in the same
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`family. In particular, Mr. Guarnieri has been intimately involved in every aspect of
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`Paice v. Hyundai, which has been ongoing since early 2012. PAICE & ABELL
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`have invested significant financial resources in each of these related matters in
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`which Mr. Guarnieri is serving as counsel. Moreover, through his representation in
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`the related matters, PAICE & ABELL has developed a particular relationship with
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`Mr. Guarnieri such that PAICE & ABELL desires to continue the relationship with
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`Mr. Guarnieri for the purpose of this proceeding.
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`Proceeding No.: IPR2014-00571
`Attorney Docket: 36351-0011IP1
`1. Declaration of Individual Seeking to Appear
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`This Motion for Pro Hac Vice Admission is accompanied by a Declaration
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`of William Peter Guarnieri as required by the Order Authorizing Motion for Pro
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`Hac Vice mailed April 11, 2014.
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`Accordingly, PAICE & ABELL submits that there is good cause under 37
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`C.F.R. § 42.10(c) for the Board to recognize William Peter Guarnieri as counsel
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`pro hac vice during this proceeding.
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`Date: April 3, 2015
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`Customer Number 26171
`Fish & Richardson P.C.
`Telephone: (202) 626-6429
`Facsimile: (202) 783-2331
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`Respectfully submitted,
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`/Timothy W. Riffe/
`Timothy W. Riffe
`Reg. No. 43,881
`Counsel for Patent Owner
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`Proceeding No.: IPR2014-00571
`Attorney Docket: 36351-0011IP1
`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(4)(i) et seq. and 42.105(b), the undersigned
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`certifies that on April 3, 2015, a complete and entire copy of this Patent Owner’s
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`Motion for Pro Hac Vice and Declaration of William Peter Guarnieri was provided
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`via electronic mail to Counsel for Petitioner by serving the correspondence address
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`of record as follows:
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`Frank A. Angileri
`Brooks Kushman P.C.
`1000 Town Center
`Twenty-Second Floor
`Southfield, Michigan 48075
`Email: FPGP0101IPR2@brookskushman.com
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`Lissi Mojica
`Kevin Greenleaf
`Dentons US LLP
`1530 Page Mill Road
`Suite 200
`Palo Alto, California 94304-11251
`Email: lissi.mojica@dentons.com
`Email: kevin.greenleaf@dentons.com
`Email: iptdocketchi@dentorns.com
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`/Susan C. Johnson/
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`Susan C. Johnson
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(214) 292-4086
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`5
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