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`Patent No. 7,147,759
`IPR2014-01086
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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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`GLOBAL FOUNDRIES U.S., INC., GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, GLOBALFOUNDRIES DRESDEN MODULE
`TWO LLC & CO. KG, and THE GILLETTE COMPANY,
`Petitioners
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`v.
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`ZOND, LLC
`Patent Owner
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`_____________________
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`Inter Partes Review Case No. IPR2014-010861
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`Patent 7,147,759 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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`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. Etai Lahav as counsel pro hac vice during this proceeding.
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`Petitioners do not oppose this motion.
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`1 Case IPR 2014-00981 has been joined with the instant proceeding.
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`1. Time for Filing
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`Patent No. 7,147,759
`IPR2014-01086
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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: 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. Lahav 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. 7,147,759 is currently asserted by the Patent
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`Owner in co-pending litigation, in the District of Massachusetts, 1:13-cv-11577-
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`LTS (Zond v. AMD, et al.) (“the co-pending litigation”). Mr. Lahav is a member
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`of the New York bar in good standing, and is representing the Patent Owner in the
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`co-pending litigation.
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`Mr. Lahav has analyzed prior art references and claim charts in connection
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`with invalidity contentions and has been involved in forming claim construction
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`Patent No. 7,147,759
`IPR2014-01086
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`positions related to the claimed inventions, all of which are relevant to the petition
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`requesting inter partes review of U.S. Patent No. 7,147,759. Patent Owner wishes
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`to apply Mr. Lahav’s knowledge of the patent by employing him as counsel in this
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`proceeding. Admission of Mr. Lahav pro hac vice will enable Patent Owner to
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`avoid unnecessary expense and duplication of work between this proceeding and
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`the co-pending litigation.
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`Patent Owner’s lead and backup counsel are registered practitioners and
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`Mr. Lahav 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. Lahav as counsel pro hac
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`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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`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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`Patent No. 7,147,759
`IPR2014-01086
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`This Motion for Pro Hac Vice Admission is supported by an Affidavit of
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`Mr. Lahav (Ex. 2001).
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`Date: November 26, 2014
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`Respectfully submitted,
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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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`Counsel for Patent Owner Zond, LLC
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`PATENT OWNER’S EXHIBIT LIST IPR2014-01086
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`Patent No. 7,147,759
`IPR2014-01086
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`Exhibit No.
`Ex. 2001
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`Ex. 2002
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`Ex. 2003
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`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
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`CERTIFICATE OF SERVICE
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`Patent No. 7,147,759
`IPR2014-01086
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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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`david.mccombs.ipr@haynesboone.com
`david.odell.ipr@haynesboone.com
`donald.jackson@haynesboone.com
`gregory.huh.ipr@haynesboone.com
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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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`6
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