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`Patent No. 6,806,652
`IPR2014-01088
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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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`GLOBALFOUNDRIES 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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`_____________________
`Inter Partes Review Case No. IPR2014-010881
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`Patent 6,806,652 B2
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`_____________________
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` PATENT OWNER’S UNOPPOSED 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 Dr. Maria Granovsky as counsel pro hac vice during this proceeding.
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`Petitioners do not oppose this motion.
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`1 Case IPR2014-01000 has been joined with the instant proceeding.
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`1. Time for Filing
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`Patent No. 6,806,652
`IPR2014-01088
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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: Tarek Fahmi, USPTO Reg. No. 41,402; and
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`Backup Counsel: Dr. Gregory J. Gonsalves, USPTO Reg. No. 43,639.
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`Dr. Granovsky 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. 6,806,652 is currently asserted by the Patent Owner in
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`co-pending litigation, in the District of Massachusetts, 1:13-cv-11577-LTS (Zond
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`v. AMD, et al.) (“the co-pending litigation”). Dr. Granovsky is a member of the
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`New York and Delaware bars in good standing, and is representing the Patent
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`Owner in the co-pending litigation.
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`Dr. Granovsky has analyzed prior art references and claim charts in
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`2
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`connection with invalidity contentions and has been involved in forming claim
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`Patent No. 6,806,652
`IPR2014-01088
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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. 6,806,652. Patent
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`Owner wishes to apply Dr. Granovsky’s knowledge of the patent by employing her
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`as counsel in this proceeding. Admission of Dr. Granovsky 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 Dr.
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`Granovsky 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 Dr. Granovsky as counsel pro
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`hac vice during this proceeding.
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`Given that there are 33 such petitions instituted over ten different patents,
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`with numerous petitioners, Patent Owner needs additional attorneys admitted to be
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`able to address the several depositions and related preparation that are expected to
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`take place in the coming weeks.
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`3
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`3. Affidavit of Individual Seeking to Appear
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`Patent No. 6,806,652
`IPR2014-01088
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`This Motion for Pro Hac Vice Admission is supported by an Affidavit of Dr.
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`Respectfully submitted,
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`
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`/Tarek N. Fahmi/
`Tarek Fahmi
`Reg. No. 41,402
`333 W. San Carlos Street, Suite 200
`San Jose, CA 95110
`(408) 799-0612
`tarek.fahmi@ascendalaw.com
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`Counsel for Patent Owner Zond, LLC
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`4
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`Granovsky (Ex. 2001).
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`Date: February 24, 2015
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`PATENT OWNER’S EXHIBIT LIST IPR2014-01088
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`Patent No. 6,806,652
`IPR2014-01088
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`Exhibit No.
`Ex. 2001
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`Description
`Affidavit of Maria Granovsky in Support of Patent
`Owner’s Motion for Pro Hac Vice Admission
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`5
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`CERTIFICATE OF SERVICE
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`Patent No. 6,806,652
`IPR2014-01088
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`I certify that the foregoing Motion for Pro Hac Vice Admission and its
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`accompanying exhibits on February 24, 2015, by filing these documents though the
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`Patent Review Processing System as well as delivering a copy via EMAIL directed
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`to the attorneys of record for the Petitioner at the following address:
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`
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`For Petitioner:
`GLOBALFOUNDRIES U.S., INC.,
`GLOBALFOUNDRIES DRESDEN
`MODULE ONE LLC & CO. KG, and
`GLOBALFOUNDRIES DRESDEN
`MODULE TWO LLC & CO. KG
`David M. Tennant
`WHITE & CASE LLP
`701 THIRTEENTH STREET, NW
`WASHINGTON, DC 20005
`dtennant@whitecase.com
`dchankong@whitecase.com
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`
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`For Petitioner:
`THE GILETTE COMPANY
`David L. Cavanaugh, Reg. No. 36,476
`Larissa Park, Reg. No. 59,051
`Wilmer Cutler Pickering Hale and
`Dorr LLP
`60 State Street
`Boston, MA 02109
`Tel: (617) 526-5000
`Email:
`david.cavanaugh@wilmerhale.com;
`Larissa.Park@wilmerhale.com
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`The parties have agreed to electronic service in this matter.
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`/Tarek N. Fahmi/
`Tarek Fahmi
`Reg. No. 41,402
`333 W. San Carlos Street, Suite 200
`San Jose, CA 95110
`(408) 799-0612
`tarek.fahmi@ascendalaw.com
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`6