`IPR2014-00604
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_____________________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_____________________
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`THE GILLETTE COMPANY, TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY, LTD., TSMC NORTH AMERICA
`CORPORATION, FUJITSU SEMICONDUCTOR LIMITED, and FUJITSU
`SEMICONDUCTOR AMERICA, INC.,
`Petitioners
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`v.
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`ZOND, LLC
`Patent Owner
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`_____________________
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`Inter Partes Review Case No. IPR2014-006041
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`Patent 6,896,775 B2
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`_____________________
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`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10(c)
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`This Motion for Pro Hac Vice admission is filed on behalf of Zond, LLC
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`(“Zond” or “Patent Owner”). Zond respectfully moves that the Board recognize
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`Mr. Etai Lahav as counsel pro hac vice during this proceeding.
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`1. Time for Filing
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` Case IPR2014-01482 has been joined with the instant proceeding.
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`Patent No. 6,896,775
`IPR2014-00604
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`This Motion for Pro Hac Vice Admission is being filed no sooner than
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`twenty-one (21) days after service of the petition. See Unified Patents, Inc. v.
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`Parallel Iron, LLC, IPR2013-00639, Paper No. 7.
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`2. Statement of Facts Showing Good Cause for Admission of Counsel
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`Pro Hac Vice
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`Petitioner has been authorized to file motions seeking admission pro hac
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`vice under 37 C.F.R. 42.10(c). (Paper No. 4). Petitioner’s lead and back-up
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`counsel are registered practitioners:
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`Lead Counsel: Bruce Barker, USPTO Reg. No. 33,291; and
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`Backup Counsel: Dr. Gregory J. Gonsalves, USPTO Reg. No. 43,639.
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`Mr. Lahav is a skilled litigator, has extensively participated in the co-
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`pending litigation in federal district court involving the patent at issue in this
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`proceeding, and if admitted, will be involved with the depositions that occur in
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`this proceeding. U.S. Patent No. 6,896,775 is currently asserted by the Patent
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`Owner in co-pending litigation, in the District of Massachusetts, 1:13-cv-11576
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`(Zond v. Gillette, et al.) (“the co-pending litigation”). Mr. Lahav is a member of
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`the New York bar in good standing, and is representing the Patent Owner in the
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`co-pending litigation.
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`Mr. Lahav has analyzed prior art references and claim charts in connection
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`with invalidity contentions and has been involved in forming claim construction
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`Patent No. 6,896,775
`IPR2014-00604
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`positions related to the claimed inventions, all of which are relevant to the
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`petition requesting inter partes review of U.S. Patent No. 6,896,775. Patent
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`Owner wishes to apply Mr. Lahav’s knowledge of the patent by employing him
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`as counsel in this proceeding. Admission of Mr. Lahav pro hac vice will enable
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`Patent Owner to avoid unnecessary expense and duplication of work between this
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`proceeding and the co-pending litigation.
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`Patent Owner’s lead and backup counsel are registered practitioners and
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`Mr. Lahav is an experienced litigation attorney having familiarity with the
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`subject matter at issue in this proceeding. Therefore, Patent Owner respectfully
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`submits that there is good cause for the Board to recognize Mr. Lahav as counsel
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`pro hac vice during this proceeding.
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`3. Affidavit of Individual Seeking to Appear
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`This Motion for Pro Hac Vice Admission is supported by an Affidavit of
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`Mr. Lahav (Ex. 2001).
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`Date: November 11, 2014
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`Respectfully submitted,
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`/Mr. Bruce Barker/
`Mr. Bruce Barker
`Reg. No. 33,291
`176 East Main Street, Suite 6
`Westborough, MA 01581
`(508) 366-3800
`bbarker@chsblaw.com
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`Counsel for Patent Owner Zond, LLC
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`Patent No. 6,896,775
`IPR2014-00604
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`PATENT OWNER’S EXHIBIT LIST IPR 2014-00604
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`Exhibit No.
`Ex. 2001
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`Description
`Affidavit of Etai Lahav
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`Ex. 2002
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`Affidavit of Maria Granovsky
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`Patent No. 6,896,775
`IPR2014-00604
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`CERTIFICATE OF SERVICE
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` certify that the foregoing Motion for Pro Hac Vice Admission, supporting
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`exhibit and Patent Owner’s Exhibit List were served on the Petitioners by email to
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`the following email addresses on November 11, 2014.
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`michael.diener@wilmerhale.com
`larissa.park@wilmerhale.com
`david.odell.ipr@haynesboone.com
`david.mccombs.ipr@haynesboone.com
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`/Bruce Barker/
`Bruce Barker
`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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