`IPR2014-01073
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_____________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_____________________
`
`GLOBAL FOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG, and
`THE GILLETTE COMPANY,
`Petitioners,
`
`v.
`
`ZOND, LLC
`Patent Owner
`
`_____________________
`
`Inter Partes Review Case No. IPR2014-010731
`
`Patent 6,805,779 B2
`
`_____________________
`
`
`
` PATENT OWNER’S MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`This unopposed Motion for Pro Hac Vice admission is filed on behalf of
`
`Zond, LLC (“Zond” or “Patent Owner”). Zond respectfully moves that the Board
`
`recognize Mr. Michael D. Sadowitz as counsel pro hac vice during this proceeding.
`
`Petitioners do not oppose this motion.
`
`
`1 Case IPR2014-001017 has been joined with the instant proceeding.
`
`
`
`Patent No. 6,805,779
`IPR2014-01073
`
`
`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
`
`Patent Owner has been authorized to file motions seeking admission pro hac
`
`vice under 37 C.F.R. 42.10(c). (Paper No. 4). Patent Owner’s lead and back-up
`
`counsel are registered practitioners:
`
`Lead Counsel: Dr. Gregory J. Gonsalves, USPTO Reg. No. 43,639; and
`
`Backup Counsel: Bruce Barker, USPTO Reg. No. 33,291.
`
`Mr. Sadowitz is a skilled litigator, has extensively participated in the co-
`
`pending litigation in federal district court involving the patent at issue in this
`
`proceeding, and if admitted, will be involved with the depositions that occur in this
`
`proceeding. U.S. Patent No. 6,805,779 is currently asserted by the Patent Owner in
`
`co-pending litigation, in the District of Massachusetts, 1:13-cv-11577-LTS (Zond
`
`v. AMD, et al.) (“the co-pending litigation”). Mr. Sadowitz is a member of the New
`
`York bar in good standing, and is representing the Patent Owner in the co-pending
`
`litigation.
`
`Mr. Sadowitz has analyzed prior art references and claim charts in
`
`2
`
`
`
`Patent No. 6,805,779
`IPR2014-01073
`
`
`connection with invalidity contentions and has been involved in forming claim
`
`construction positions related to the claimed inventions, all of which are relevant to
`
`the petition requesting inter partes review of U.S. Patent No. 6,805,779. Patent
`
`Owner wishes to apply Mr. Sadowitz’s knowledge of the patent by employing him
`
`as counsel in this proceeding. Admission of Mr. Sadowitz 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 Mr.
`
`Sadowitz 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 Mr. Sadowitz as counsel pro
`
`hac vice during this proceeding.
`
`Patent Owner is filing (or has filed) motions to admit three additional
`
`attorneys (Tigran Vardanian, Etai Lahav, and Maria Granovsky) pro hac vice to all
`
`the petitions associated with U.S. Patents 6853142, 7147759, 7604716, 7808184,
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`7811421, 6896775, 8125155, and 6896773. Given that there are 25 such petitions
`
`instituted over eight different patents, with numerous petitioners, Patent Owner
`
`needs additional attorneys admitted to be able to address the several depositions
`
`and related preparation that are expected to take place in the coming weeks.
`
`3. Affidavit of Individual Seeking to Appear
`
`3
`
`
`
`This Motion for Pro Hac Vice Admission is supported by an Affidavit of
`
`Patent No. 6,805,779
`IPR2014-01073
`
`
`Mr. Sadowitz (Ex. 2001).
`
`
`
`Date: January 8, 2015
`
`Respectfully submitted,
`
`
`
`
`
`/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
`
`Counsel for Patent Owner Zond, LLC
`
`
`
`
`
`
`
`
`
`4
`
`
`
`Patent No. 6,805,779
`IPR2014-01073
`
`
`PATENT OWNER’S EXHIBIT LIST IPR2014-01073
`
`
`
`Exhibit No.
`Ex. 2001
`
`Description
`Affidavit of Michael D. Sadowitz in Support of
`Patent Owner’s Motion for Pro Hac Vice Admission
`
`
`
`
`
`
`5
`
`
`
`CERTIFICATE OF SERVICE
`
`Patent No. 6,805,779
`IPR2014-01073
`
`
`
`
`I certify that the foregoing Motion for Pro Hac Vice Admission was served
`
`on the Petitioner by email to the following email addresses on January 8, 2015.
`
`
`
`dtennant@whitecase.com
`dohm.chankong@whitecase.com
`michael.diener@wilmerhale.com
`larissa.park@wilmerhale.com
`
`
`
`/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
`
`6
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