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Patent No. 7,147,759
`IPR2014-01083
`
`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. IPR2014-010831
`
`Patent 7,147,759 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 Dr. Maria Granovsky as counsel pro hac vice during this proceeding.
`
`Petitioners do not oppose this motion.
`
`1. Time for Filing
`                                                            
`1 Case IPR 2014-00988 has been joined with the instant proceeding.
`
`

`

`This Motion for Pro Hac Vice Admission is being filed no sooner than
`
`Patent No. 7,147,759
`IPR2014-01083
`
` 
`
`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
`
`Petitioner has been authorized to file motions seeking admission pro hac
`
`vice under 37 C.F.R. 42.10(c). (Paper No. 3). Petitioner’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.
`
`Dr. Granovsky is a skilled litigator, has extensively participated in co-
`
`pending litigation in federal district court involving the subject matter of the
`
`patent at issue in this proceeding, and if admitted, will be involved with the
`
`depositions that occur in this proceeding. Dr. Granovsky is familiar with the
`
`subject matter, claim construction, and prior art at issue in this proceeding as a
`
`result of her representation of Zond, LLC, in litigation in which the patents
`
`6896775, 6896773, 6806651, 6903511, 7095179, and 7446479 have been asserted
`
`against several TSMC and Fujitsu entities. Zond v. TSMC, et al., No. 1:14-cv-
`
`12438-WGY, D. Mass. Dr. Granovsky is a member of the New York and
`
`Delaware bars in good standing, and is representing the Patent Owner in the co-
`
`2
`
`

`

` 
`pending litigation.
`
`Patent No. 7,147,759
`IPR2014-01083
`
`Dr. Granovsky has analyzed the prior art references and invalidity
`
`arguments and is familiar with the claim construction positions of the petitioners
`
`and Zond, all of which are relevant to the petition requesting inter partes review
`
`of U.S. Patent No. 7,147,759. Patent Owner wishes to apply Dr. Granovsky’s
`
`knowledge of the subject matter of this proceeding and related district court
`
`litigation by employing her as counsel. Admission of Dr. Granovsky 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 Dr.
`
`Granovsky 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 Dr. Granovsky 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, 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
`
`3
`
`

`

` 
`depositions and related preparation that are expected to take place in the coming
`
`Patent No. 7,147,759
`IPR2014-01083
`
`weeks.
`
`3. Affidavit of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is supported by an Affidavit of
`
`Dr. Granovsky (Ex. 2002).
`
`
`
`Date: November 26, 2014
`
`
`
`Respectfully submitted,
`
`
`
`/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. 7,147,759
`IPR2014-01083
`
`PATENT OWNER’S EXHIBIT LIST IPR2014-01083
`
`
`
`Description
`Affidavit of Etai Lahav in Support of Patent Owner’s
`Motion for Pro Hac Vice Admission
`Affidavit of Maria Granovsky 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
`
`Exhibit No.
`Ex. 2001
`
`Ex. 2002
`
`Ex. 2003
`
`
`
`
`
` 
`
`
`
`5
`
`

`

`Patent No. 7,147,759
`IPR2014-01083
`
`
`CERTIFICATE OF SERVICE
`
` certify that the foregoing Motion for Pro Hac Vice Admission was served
`
` I
`
` 
`
`on the Petitioner by email to the following email addresses on November 26, 2014:
`
`david.mccombs.ipr@haynesboone.com
`david.odell.ipr@haynesboone.com
`donald.jackson@haynesboone.com
`gregory.huh.ipr@haynesboone.com
`
`
`
`
`
`
`
`/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
`
`6
`
`

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