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` UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PETROLEUM GEO-SERVICES INC.
` Petitioner
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` v.
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`WESTERNGECO LLC
` Patent Owner
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` Case No. IPR2014-00689
` Patent No. 7,293,520
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`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE OF
`CHRISTOPHER A. SUAREZ UNDER 37 C.F.R. § 42.10(C)
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`Pursuant to 37 C.F.R. § 42.10(c), Petitioner Petroleum Geo-Services Inc.
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`(PGS) respectfully submits this Motion For Admission Pro Hac Vice of
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`Christopher A. Suarez, who was designated backup counsel upon filing of the
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`Petition. Petitioner respectfully requests that the Board grant the motion.
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`Although Mr. Suarez has already passed the USPTO Registration Examination, the
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`Board has instructed Petitioner to file this Motion because Mr. Suarez has not yet
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`received a registration number.
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`I.
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`INTRODUCTION
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`Section 42.10(c) of 37 C.F.R. provides that:
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`The Board may recognize counsel pro hac vice during a proceeding
`upon a showing of good cause, subject to the condition that lead
`counsel be a registered practitioner and to any conditions as the Board
`may impose.
`In this case, lead counsel (Jessamyn Berniker, Reg. No. 72,328) is a registered
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`practitioner before the USPTO. The Board recently explained its other conditions
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`for pro hac vice admission in an order in Unified Patents, Inc. v. Parallel Iron,
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`LLC, IPR2013-00639, Paper 7 (October 15, 2013). These conditions are met here,
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`as explained in the required statement of facts below and the accompanying
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`affidavit of Christopher A. Suarez attached to this motion, as required by the
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`Board. See id. at 3.
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`II.
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`STATEMENT OF FACTS
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`There is good cause to admit Christopher A. Suarez as backup counsel pro
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`hac vice in this case. Mr. Suarez is a member of the State Bar of Illinois and
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`District of Columbia. See Suarez Decl. ¶ 1. He has a thorough understanding of
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`patent law, as well as patent office rules and procedures. For example, he recently
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`completed a clerkship on the United States Court of Appeals for the Federal
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`Circuit. Id. ¶ 4. Furthermore, he has already passed the USPTO registration
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`2
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`examination. He passed on March 18, 2014 and notice has already appeared in the
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`USPTO’s Official Gazette indicating his intent to register to practice. Id. ¶¶ 2-3.
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`Although his registration awaits final approval, he avers that “[t]o the best of [his]
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`knowledge, no comments have been filed to this date that would adversely affect
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`[his] eligibility to practice before the USPTO, and [he] has no reason to expect that
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`any such comments would be filed.” See id. ¶ 3. Thus, it appears likely that he will
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`receive a USPTO registration number shortly.
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`Beyond Mr. Suarez’s qualifications to practice patent law generally, he has
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`the requisite familiarity with the subject matter in this case specifically. He has
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`been involved with the case for more than four months, has read background
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`materials pertaining to the technology at issue in this case, and has worked
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`extensively with experts who have explained concepts relating to marine seismic
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`surveying and control systems to him at length. See id. ¶ 11. Moreover, he has a
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`degree in Electrical Engineering and Computer Science from M.I.T., which has
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`applicability to the computerized control system technology implicated by the
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`challenged patent claims. Id.
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`Finally, beyond Mr. Suarez’s qualifications to practice patent law before the
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`USPTO and his familiarity with the relevant subject matter, Mr. Suarez has
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`attested to the other requirements outlined by the Board in its Pro Hac Vice Order.
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`See Unified Patents, Paper 7, at 3. He has averred that he has never been
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`3
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`suspended or disbarred from practice in any forum, has never been denied in an
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`application for admission to a court or administrative body, and has never received
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`contempt citations from a court or administrative body. See id. ¶¶ 5-7. Finally, he
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`has averred that he has read and will comply with the rules outlined in the Office
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`Patent Trial Practice Guide and the Board’s Rules of Practice for Trials, and that he
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`will comply with the USPTO Rules of Professional Conduct and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a). Id. ¶¶ 8-9. He has never applied for pro
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`hac vice admissions in other proceedings prior to this date. Id. ¶ 10.
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`III. CONCLUSION
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`For the foregoing reasons, Petitioner respectfully requests that the Board
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`admit Christopher A. Suarez pro hac vice in this proceeding.
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`Dated: April 29, 2014
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` Respectfully Submitted,
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`4
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`_________________
`Jessamyn Berniker
`Reg. No. 72,328
`Williams & Connolly, LLP
`725 12th St., NW
`Washington, DC 20005
`Telephone: 202-434-5000
`Facsimile: 202-434-5957
`Email: jberniker@wc.com
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`Attorney for Petitioner
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the above-captioned Petroleum Geo-
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`Service Inc.’s “Petitioner’s Motion for Admission Pro Hac Vice of Christopher A.
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`Suarez Under 37 C.F.R. § 42.10(c)” was served on the 29th day of April, 2014, on
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`the Patent Owner at the official correspondence address for the attorney of record
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`for the ʼ520 Patent as shown in USPTO PAIR via FedEx:
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`WesternGeco L.L.C.
`10001 Richmond Avenue
`IP Administration Center of Excellence
`Houston TX 77042
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`DATE: April 29, 2014.
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`_________________________
`Jessamyn Berniker
`Reg. No. 72,328
`Williams & Connolly, LLP
`725 12th St., NW
`Washington, DC 20005
`Telephone: 202-434-5000
`Facsimile: 202-434-5957
`Email: jberniker@wc.com
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`Attorney for Petitioner
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