`IPR2014-00803
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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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`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
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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. IPR2014-00803
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`Patent 7,808,184 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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`Patent No. 7,808,184
`IPR2014-00803
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`Dr. Maria Granovsky as counsel pro hac vice during this proceeding.
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`1. Time for Filing
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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. 3). 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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`Dr. Granovsky is a skilled litigator, has extensively participated in co-
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`pending litigation in federal district court involving the subject matter of the
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`patent at issue in this proceeding, and if admitted, will be involved with the
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`depositions that occur in this proceeding. Dr. Granovsky is familiar with the
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`subject matter, claim construction, and prior art at issue in this proceeding as a
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`result of her representation of Zond, LLC, in litigation in which the patents
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`6896775, 6896773, 6806651, 6903511, 7095179, and 7446479 have been
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`asserted against several TSMC and Fujitsu entities. Zond v. TSMC, et al., No.
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`2
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`1:14-cv-12438-WGY, D. Mass. Dr. Granovsky is a member of the New York
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`and Delaware bars in good standing, and is representing the Patent Owner in the
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`Patent No. 7,808,184
`IPR2014-00803
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`co-pending litigation.
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`Dr. Granovsky has analyzed the prior art references and invalidity
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`arguments and is familiar with the claim construction positions of the petitioners
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`and Zond, all of which are relevant to the petition requesting inter partes review
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`of U.S. Patent No. 7,808,184. Patent Owner wishes to apply Dr. Granovsky’s
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`knowledge of the subject matter of this proceeding and related district court
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`litigation by employing her as counsel. Admission of Dr. Granovsky pro hac vice
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`will 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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`Dr. Granovsky 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 Dr. Granovsky as
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`counsel pro hac vice during this proceeding.
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`Patent No. 7,808,184
`IPR2014-00803
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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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`Dr. Granovsky (Ex. 2006).
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`Date: November 11, 2014
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`Respectfully submitted,
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`
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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. 7,808,184
`IPR2014-00803
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`PATENT OWNER’S EXHIBIT LIST IPR 2014-00803
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`Exhibit No.
`Ex. 2001
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`Ex. 2002
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`Description
`Information Disclosure Statement
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`Webster’s New World College Dictionary, 4th
`Edition, 2008
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`Ex. 2003
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`U.S. Patent No. 6,896,773
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`Ex. 2004
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`Ex. 2005
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`U.S. Patent No. 6,806,652
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`Affidavit of Etai Lahav
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`Ex. 2006
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`Affidavit of Maria Granovsky
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`Patent No. 7,808,184
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`CERTIFICATE OF SERVICE
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` I
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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 Petitioner by email to
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`the following email addresses on November 11, 2014:
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`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
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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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