throbber
Patent No. 7,604,716
`IPR2014-00808
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________________
`
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY LTD, AND
`TSMC NORTH AMERICA CORP.
`
`Petitioner
`
`v.
`
`ZOND, LLC
`Patent Owner
`
`U.S. Patent No. 7,604,716
`
`_____________________
`
`Inter Partes Review Case No. 2014-00808
`_____________________
`
`PATENT OWNER'S MOTION FOR COUNSEL TO
`WITHDRAW FROM THE PROCEEDING AND PERMIT
`SUBSTITUTION OF COUNSEL
`
`
`
`
`
`
`
`

`
`Patent No. 7,604,716
`IPR2014-00808
`
`
`
`I.
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.10, Patent Owner Zond, LLC ("Zond")
`
`respectfully requests that the Patent Trial and Appeal Board ("the Board")
`
`authorize withdrawal of its current lead counsel, Bruce J. Barker, and substitution
`
`of new lead counsel, Tarek Fahmi.
`
`II.
`
`STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO AUTHORIZE WITHDRAWAL OF COUNSEL
`
`Bruce Barker was appointed by Zond as its attorney for the above-captioned
`
`inter partes review. Patent Owner Zond now requests that current designated
`
`counsel be allowed to withdraw from the present proceeding, and that new counsel
`
`listed below be substituted as lead counsel for Zond in this proceeding.
`
`Lead Counsel:
`
`Tarek Fahmi
`Reg. No. 41,402
`84 W. Santa Clara Street, Suite 550
`San Jose, CA 95113
`408-799-0612
`tarek.fahmi@ascendalaw.com
`
`Mr. Fahmi meets the requirements of 37 C.F.R. § 42.10(c) as lead counsel and is a
`
`registered practitioner. In addition Mr. Fahmi has read and intends to comply with
`
`the Patent Office Trial Practice Guide and the Board's Rules of Practice for Trials,
`
`as set forth in Part 42 of the C.F.R.
`
`
`
`1
`
`

`
`Patent No. 7,604,716
`IPR2014-00808
`
`
`
`
`Accordingly, Patent Owner Zond respectfully requests that the Board grant
`
`its motion to authorize withdrawal of counsel. Upon grant of this motion, current
`
`counsel for Zond will promptly file a new Power of Attorney (as attached hereto)
`
`and an Amended Mandatory Notice Information.
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`/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
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Date: November 3, 2014
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`2
`
`

`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`TAIWAN SEMICONDUCTOR MANUFACTURING COMPANY LTD, AND
`
`TSMC NORTH AMERICA CORP.
`
`Petitioner
`
`v.
`
`ZOND, LLC,
` Patent Owner
`
`Case IPR2014 – 00808
`U.S. Patent 7,604,716
`
`POWER OF ATTORNEY FOR ZOND, LLC
`
`The undersigned duly authorized representative of Zond, LLC hereby appoints the
`
`following practitioners as its representatives before the United States Patent and
`
`Trademark Office in connection with Case No. IPR2014-00808:
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Back-up Counsel
`Dr. Gregory J. Gonsalves
`Reg. No. 43,639
`2216 Beacon Lane
`Falls Church, Virginia
`(571) 419-7252
`gonsalves@gonsalveslawfirm.com
`
`
`Respectfully submitted,
`
`_________________________________________
`For: Zond, LLC
`Name: Bassam Abraham
`Title: Vice President
`
`
`
`Lead Counsel
`
`Tarek Fahmi
`Reg. No. 41,402
`84 W. Santa Clara Street, Suite 550
`San Jose, CA 95113
`408-799-0612
`tarek.fahmi@ascendalaw.com
`
`
`
`
`November 3, 2014
`Date: ______________
`
`
`
`

`
`Patent No. 7,604,716
`IPR2014-00808
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Patent
`
`Owner’s Motion For Counsel To Withdraw From The Proceeding and Permit
`
`Substitution Of Counsel and the associated Power of Attorney documents were
`
`served via email on November 3, 2014, on the attorneys for the Petitioner:
`
` 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
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`/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
`
`3

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