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`Patent No. 6,896,775
`IPR2014-00578
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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 CORP.,
`FUJITSU SEMICONDUCTOR LIMITED, and FUJITSU SEMICONDUCTOR
`AMERICA, INC.
`
`Petitioners
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`v.
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`ZOND, LLC
`Patent Owner
`
`_____________________
`Case No. IPR2014-006041
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`Patent 6,896,775 B2
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`_____________________
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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 unopposed Motion for Pro Hac Vice admission is filed on behalf of
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`Zond, LLC (“Zond” or “Patent Owner”). Zond respectfully moves that the Board
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`recognize Mr. Tigran Vardanian as counsel pro hac vice during this proceeding.
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`1 Cases IPR 2014-01482 have been joined with the instant proceeding.
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`Petitioners do not oppose this motion.
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`1. Time for Filing
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`Patent No. 6,896,775
`IPR2014-00578
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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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`Patent Owner has been authorized to file motions seeking admission pro
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`hac vice under 37 C.F.R. 42.10(c). (Paper No. 4). Patent Owner’s lead and back-
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`up counsel are registered practitioners:
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`Lead Counsel: Tarek N. Fahmi, USPTO Reg. No. 41,402; and
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`Backup Counsel: Dr. Gregory J. Gonsalves, USPTO Reg. No. 43,639.
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`Mr. Vardanian 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, 1:14-cv-12438-
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`WGY (Zond v. Gillette, et al.) (“the co-pending litigation”). Mr. Vardanian is a
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`member of the New York and Illinois bars in good standing, and is representing
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`the Patent Owner in the co-pending litigation.
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`2
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`Mr. Vardanian has analyzed prior art references and claim charts in
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`Patent No. 6,896,775
`IPR2014-00578
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`connection with invalidity contentions and has been involved in forming claim
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`construction positions related to the claimed inventions, all of which are relevant
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`to the petition requesting inter partes review of U.S. Patent No. 6,896,775. Patent
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`Owner wishes to apply Mr. Vardanian’s knowledge of the patent by employing
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`him as counsel in this proceeding. Admission of Mr. Vardanian pro hac vice will
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`enable Patent Owner to avoid unnecessary expense and duplication of work
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`between this 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. Vardanian 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. Vardanian as
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`counsel pro hac vice during this proceeding.
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`Patent Owner is filing (or has filed) motions to admit three additional
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`attorneys (Tigran Vardanian, Etai Lahav, and Maria Granovsky) pro hac vice to
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`all the petitions associated with U.S. Patents 6853142, 7147759, 7604716,
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`7808184, 7811421, 6896775, 8125155, and 6896773. Given that there are 25
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`such petitions instituted over eight different patents, with numerous petitioners,
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`Patent Owner needs additional attorneys admitted to be able to address the several
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`depositions and related preparation that are expected to take place in the coming
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`3
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`weeks.
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`Patent No. 6,896,775
`IPR2014-00578
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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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`Respectfully submitted,
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`
`
`/Tarek N. Fahmi/
`
`
`Tarek N. Fahmi, Reg. No. 41,402
`Ascenda Law Group, PC
`84 W. Santa Clara St., Suite 550
`San Jose, CA 95113-1812
`1 866 877 4883
`tarek.fahmi@ascendalaw.com
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`Counsel for Patent Owner Zond, LLC
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`
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`Mr. Vardanian (Ex. 2003).
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`Date: November 26, 2014
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`4
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`PATENT OWNER’S EXHIBIT LIST IPR2014-00578
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`Patent No. 6,896,775
`IPR2014-00578
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`
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`Exhibit No.
`Ex. 2001
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`Ex. 2002
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`Ex. 2003
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`Description
`Affidavit of Etai Lahav in Support of Patent Owner’s
`Motion for Pro Hac Vice Admission
`Affidavit of Maria Granovsky in Support of Patent
`Owner’s Motion for Pro Hac Vice Admission
`Affidavit of Tigran Vardanian in Support of Patent
`Owner’s Motion for Pro Hac Vice Admission
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`5
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a copy of the foregoing:
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`Patent No. 6,896,775
`IPR2014-00578
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`PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10(c)
`and its supporting exhibits was served on November 26, 2014, by filing this
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`document though the Patent Review Processing System as well as delivering a copy via
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`EMAIL directed to the attorneys of record for the Petitioner at the following address:
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`For Petitioner:
`TAIWAN SEMICONDUCTOR
`MANUFACTURING COMPANY
`LTD, AND TSMC NORTH
`AMERICA CORP., FUJITSU
`SEMICONDUCTOR LIMITED AND
`FUJITSU SEMICONDUCTOR
`AMERICA, INC.
`David L. McCombs, Reg. No. 32,271
`David M. O’Dell, Reg. No. 42,044
`Haynes and Boone, LLP
`2323 Victory Avenue, Suite 700
`Dallas, TX 75219
`Tel: (214) 651-5533
`Email:
`David.McCombs@haynesboone.com;
`david.odell@haynesboone.com
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`6
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`For Petitioner:
`THE GILETTE COMPANY
`Michael A. Diener, Reg. No. 37,122
`Larissa Park, Reg. No. 59,051
`Wilmer Cutler Pickering Hale and
`Dorr LLP
`60 State Street
`Boston, MA 02109
`Tel: (617) 526-5000
`Email:
`Michael.Diener@wilmerhale.com;
`Larissa.Park@wilmerhale.com
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`Patent No. 6,896,775
`IPR2014-00604
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`The parties have agreed to electronic service in this matter.
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`Respectfully submitted,
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`
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`Date: November 26, 2014
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` by:
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`
`
` /Tarek N. Fahmi/
`Tarek N. Fahmi, Reg. No. 41,402
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`
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`Ascenda Law Group, PC
`84 W. Santa Clara St., Suite 550
`San Jose, CA 95113-1812
`1 866 877 4883