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Patent No. 7,808,184
`IPR2014-00803
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY, LTD.,
`TSMC NORTH AMERICA CORPORATION, ADVANCED MICRO DEVICES,
`INC., RENESAS ELECTRONICS CORPORATION, RENESAS ELECTRONICS
`AMERICA, INC., GLOBALFOUNDRIES U.S., INC., GLOBALFOUNDRIES
`DRESDEN MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG, TOSHIBA AMERICA ELECTRONIC
`COMPONENTS, INC., TOSHIBA AMERICA INC., TOSHIBA AMERICA
`INFORMATION SYSTEMS, INC., TOSHIBA CORPORATION, and
`THE GILLETTE CO.
`Petitioners
`
`v.
`
`ZOND, LLC
`Patent Owner
`
`_____________________
`
`Inter Partes Review Case No. IPR2014-00803
`
`Patent 7,808,184 B2
`
`_____________________
`
`
` PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`
`This Motion for Pro Hac Vice admission is filed on behalf of Zond, LLC
`
`(“Zond” or “Patent Owner”). Zond respectfully moves that the Board recognize
`
`

`

`Patent No. 7,808,184
`IPR2014-00803
`
`
`
`Dr. Maria Granovsky as counsel pro hac vice during this proceeding.
`
`1. Time for Filing
`
`This Motion for Pro Hac Vice Admission is being filed no sooner than
`
`twenty-one (21) days after service of the petition. See Unified Patents, Inc. v.
`
`Parallel Iron, LLC, IPR2013-00639, Paper No. 7.
`
`2. Statement of Facts Showing Good Cause for Admission of Counsel
`
`Pro Hac Vice
`
`Petitioner has been authorized to file motions seeking admission pro hac
`
`vice under 37 C.F.R. 42.10(c). (Paper No. 3). Petitioner’s lead and back-up
`
`counsel are registered practitioners:
`
`Lead Counsel: Bruce Barker, USPTO Reg. No. 33,291; and
`
`Backup Counsel: Dr. Gregory J. Gonsalves, USPTO Reg. No. 43,639.
`
`Dr. Granovsky is a skilled litigator, has extensively participated in co-
`
`pending litigation in federal district court involving the subject matter of the
`
`patent at issue in this proceeding, and if admitted, will be involved with the
`
`depositions that occur in this proceeding. Dr. Granovsky is familiar with the
`
`subject matter, claim construction, and prior art at issue in this proceeding as a
`
`result of her representation of Zond, LLC, in litigation in which the patents
`
`6896775, 6896773, 6806651, 6903511, 7095179, and 7446479 have been
`
`asserted against several TSMC and Fujitsu entities. Zond v. TSMC, et al., No.
`
`2
`
`

`

`
`
`1:14-cv-12438-WGY, D. Mass. Dr. Granovsky is a member of the New York
`
`and Delaware bars in good standing, and is representing the Patent Owner in the
`
`Patent No. 7,808,184
`IPR2014-00803
`
`co-pending litigation.
`
`Dr. Granovsky has analyzed the prior art references and invalidity
`
`arguments and is familiar with the claim construction positions of the petitioners
`
`and Zond, all of which are relevant to the petition requesting inter partes review
`
`of U.S. Patent No. 7,808,184. Patent Owner wishes to apply Dr. Granovsky’s
`
`knowledge of the subject matter of this proceeding and related district court
`
`litigation by employing her as counsel. Admission of Dr. Granovsky pro hac vice
`
`will enable Patent Owner to avoid unnecessary expense and duplication of work
`
`between this proceeding and the co-pending litigation.
`
`Patent Owner’s lead and backup counsel are registered practitioners and
`
`Dr. Granovsky is an experienced litigation attorney having familiarity with the
`
`subject matter at issue in this proceeding. Therefore, Patent Owner respectfully
`
`submits that there is good cause for the Board to recognize Dr. Granovsky as
`
`counsel pro hac vice during this proceeding.
`
`
`
`
`
`3
`
`

`

`Patent No. 7,808,184
`IPR2014-00803
`
`
`
`
`
`3. Affidavit of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is supported by an Affidavit of
`
`Dr. Granovsky (Ex. 2006).
`
`
`
`Date: November 11, 2014
`
`Respectfully submitted,
`
`
`
`/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
`
`Counsel for Patent Owner Zond, LLC
`
`
`
`
`
`
`
`4
`
`

`

`Patent No. 7,808,184
`IPR2014-00803
`
`PATENT OWNER’S EXHIBIT LIST IPR 2014-00803
`
`Exhibit No.
`Ex. 2001
`
`Ex. 2002
`
`Description
`Information Disclosure Statement
`
`Webster’s New World College Dictionary, 4th
`Edition, 2008
`
`Ex. 2003
`
`U.S. Patent No. 6,896,773
`
`Ex. 2004
`
`Ex. 2005
`
`U.S. Patent No. 6,806,652
`
`Affidavit of Etai Lahav
`
`Ex. 2006
`
`Affidavit of Maria Granovsky
`
`
`
`
`
`
`
`
`
`5
`
`

`

`Patent No. 7,808,184
`IPR2014-00803
`
`
`
`
`CERTIFICATE OF SERVICE
`
` I
`
` certify that the foregoing Motion for Pro Hac Vice Admission, supporting
`
`exhibit, and Patent Owner’s Exhibit list were served on the Petitioner by email to
`
`the following email addresses on November 11, 2014:
`
`David.odell.ipr@haynesboone.com
`david.mccombs.ipr@haynesboone.com
`rckim@duanemorris.com
`Michael.Diener@wilmerhale.com
`Larissa.Park@wilmerhale.com
`dtennant@whitecase.com
`bberliner@omm.com
`ryagura@omm.com
`vzhou@omm.com
`jfeldhaus@foley.com
`pagarwal@foley.com
`mhouston@foley.com
`Robinson.vu@bakerbotts.com
`AJFitzpatrick@duanemorris.com
`
`/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
`
`
`6
`
`
`
`
`
`
`

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