`
`Patent No. 7,147,759
`IPR2014-01086
`
`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. IPR2014-010861
`
`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 Mr. Tigran Vardanian as counsel pro hac vice during this proceeding.
`
`Petitioners do not oppose this motion.
`
`
`1 Case IPR 2014-00981 has been joined with the instant proceeding.
`
`
`
`1. Time for Filing
`
`Patent No. 7,147,759
`IPR2014-01086
`
`
`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. 3). 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. Vardanian 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. 7,147,759 is currently asserted by the Patent
`
`Owner in co-pending litigation, in the District of Massachusetts, 1:13-cv-11634-
`
`WGY (Zond v. Fujitsu, et al.) (“the co-pending litigation”). Mr. Vardanian is a
`
`member of the New York and Illinois bars in good standing, and is representing
`
`the Patent Owner in the co-pending litigation.
`
`Mr. Vardanian has analyzed prior art references and claim charts in
`
`2
`
`
`
`connection with invalidity contentions and has been involved in forming claim
`
`Patent No. 7,147,759
`IPR2014-01086
`
`
`construction positions related to the claimed inventions, 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 Mr. Vardanian’s knowledge of the patent by employing
`
`him as counsel in this proceeding. Admission of Mr. Vardanian 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. Vardanian 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. Vardanian 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,
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`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
`
`depositions and related preparation that are expected to take place in the coming
`
`weeks.
`
`3
`
`
`
`3. Affidavit of Individual Seeking to Appear
`
`Patent No. 7,147,759
`IPR2014-01086
`
`
`This Motion for Pro Hac Vice Admission is supported by an Affidavit of
`
`
`
`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
`
`Mr. Vardanian (Ex. 2003).
`
`Date: November 26, 2014
`
`
`
`
`
`
`
`
`
`PATENT OWNER’S EXHIBIT LIST IPR2014-01086
`
`Patent No. 7,147,759
`IPR2014-01086
`
`
`
`
`Exhibit No.
`Ex. 2001
`
`Ex. 2002
`
`Ex. 2003
`
`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
`
`
`
`
`
`
`5
`
`
`
`CERTIFICATE OF SERVICE
`
`Patent No. 7,147,759
`IPR2014-01086
`
`
`
`
`I certify that the foregoing Motion for Pro Hac Vice Admission was served
`
`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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