`IPR2014-00917
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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,
`FUJITSU SEMICONDUCTOR LIMITED,
`FUJITSU SEMICONDUCTOR AMERICA, INC.,
`ADVANCED MICRO DEVICES, INC., RENESAS ELECTRONICS
`CORPORATION, RENESAS ELECTRONICS AMERICA, INC.,
`GLOBAL FOUNDRIES 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 COMPANY,
`Petitioners,
`v.
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`ZOND, LLC,
`Patent Owner
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`_____________________
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`Inter Partes Review Case No. IPR2014-009171
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`Patent 6,805,779 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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`1 Case IPR2014-00918, IPR2014-01074, and IPR2014-01025 have been
`joined with the instant proceeding.
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`
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`Patent No. 6,805,779
`IPR2014-00917
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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 hac
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`vice under 37 C.F.R. 42.10(c). (Paper No. 3). Patent Owner’s lead and back-up
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`counsel are registered practitioners:
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`Lead Counsel: Dr. Gregory J. Gonsalves, USPTO Reg. No. 43,639; and
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`Backup Counsel: Bruce Barker, USPTO Reg. No. 33,291.
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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 this
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`proceeding. U.S. Patent No. 6,805,779 is currently asserted by the Patent Owner in
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`Patent No. 6,805,779
`IPR2014-00917
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`co-pending litigation, in the District of Massachusetts, 1:13-cv-11634-WGY (Zond
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`v. Fujitsu, et al.) (“the co-pending litigation”). Mr. Vardanian is a member of the
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`New York and Illinois bars in good standing, and is representing the Patent Owner
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`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 to
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`the petition requesting inter partes review of U.S. Patent No. 6,805,779. 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 Mr.
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`Vardanian is an experienced litigation attorney having familiarity with the subject
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`matter at issue in this proceeding. Therefore, Patent Owner respectfully submits
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`that there is good cause for the Board to recognize Mr. Vardanian as counsel pro
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`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 (Etai Lahav, Maria Granovsky, and Michael Sadowitz) pro hac vice to all
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`the petitions associated with U.S. Patents 6853142, 7147759, 7604716, 7808184,
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`Patent No. 6,805,779
`IPR2014-00917
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`7811421, 8125155, 6896775, 6896773, 6805779, and 6806652. Given that there
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`are 33 such petitions instituted over ten different patents, with numerous
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`petitioners, Patent Owner needs additional attorneys admitted to be able to address
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`the several depositions and related preparation that are expected to take place in the
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`coming 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. 2002).
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`
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`Date: January 15, 2015
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`Respectfully submitted,
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`
`
`
`
`/Dr. Gregory J. Gonsalves/
`Dr. Gregory J. Gonsalves
`Reg. No. 43,639
`2216 Beacon Lane
`Falls Church, Virginia 22043
`(571) 419-7252
`gonsalves@gonsalveslawfirm.com
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`Counsel for Patent Owner Zond, LLC
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`Patent No. 6,805,779
`IPR2014-00917
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`PATENT OWNER’S EXHIBIT LIST IPR2014-00917
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`
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`Exhibit No.
`Ex. 2001
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`Ex. 2002
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`Description
`Affidavit of Michael D. Sadowitz in Support of
`Patent Owner’s Motion for Pro Hac Vice Admission
`Affidavit of Tigran Vardanian in Support of Patent
`Owner’s Motion for Pro Hac Vice Admission
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`CERTIFICATE OF SERVICE
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`Patent No. 6,805,779
`IPR2014-00917
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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 January 15, 2015.
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`
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`david.odell.ipr@haynesboone.com
`david.mccombs.ipr@haynesboone.com
`rckim@duanemorris.com
`robinson.vu@bakerbotts.com
`jfeldhaus@foley.com
`pagarwal@foley.com
`mhouston@foley.com
`dtennant@whitecase.com
`bberliner@omm.com
`ryagura@omm.com
`vzhou@omm.com
`michael.diener@wilmerhale.com
`larissa.park@wilmerhale.com
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`
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`/Dr. Gregory J. Gonsalves/
`Dr. Gregory J. Gonsalves
`Reg. No. 43,639
`2216 Beacon Lane
`Falls Church, Virginia 22043
`(571) 419-7252
`gonsalves@gonsalveslawfirm.com
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