`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
`
`_____________________
`
`Inter Partes Review Case No. IPR2014-008031
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`Patent 7,808,184 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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`1
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` Cases IPR 2014-00858, IPR 2014-010996, and IPR 2014-01061 have been joined
`with the instant proceeding.
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`
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`Patent No. 7,808,184
`IPR2014-00803
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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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`Petitioners do not oppose this motion.
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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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`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. 3). Patent Owner’s lead and back-
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`up 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. 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. 7,808,184 is currently asserted by the Patent
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`Owner in co-pending litigation, in the District of Massachusetts, 1:13-cv-11634-
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`2
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`Patent No. 7,808,184
`IPR2014-00803
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`WGY (Zond v. Fujitsu, 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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`Mr. Vardanian has analyzed prior art references and claim charts in
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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. 7,808,184. 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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`3
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`Patent No. 7,808,184
`IPR2014-00803
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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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`weeks.
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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. Vardanian (Ex. 2010).
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`Date: November 26, 2014
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`Respectfully submitted,
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`
`
`/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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`Counsel for Patent Owner Zond, LLC
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`4
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`
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`Patent No. 7,808,184
`IPR2014-00803
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`PATENT OWNER’S EXHIBIT LIST IPR2014-00803
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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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`Ex. 2007
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`U.S. Patent No. 6,398,929
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`Ex. 2008
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`Copy of Kudryavtsev Annotated by Mr.
`DeVito
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`Ex. 2009
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`Powell on Thin Films
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`Ex. 2010
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`Affidavit of Tigran Vardanian
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`5
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`CERTIFICATE OF SERVICE
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`Patent No. 7,808,184
`IPR2014-00803
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`I certify that the foregoing Motion for Pro Hac Vice Admission was served
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`on the Petitioner by email to the following email addresses on November 26, 2014.
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`
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`
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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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`
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`
`
`/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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`6
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