UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`LG DISPLAY CO., LTD.
`Petitioner
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`Patent Owner
`_______________
`
`Case: IPR2014-01096
`
`Patent 7,537,370
`_______________
`
`PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION OF JAMIE
`B. BEABER PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________
`
`LG DISPLAY CO., LTD.
`Petitioner
`
`v.
`
`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`Patent Owner
`_______________
`
`Case: IPR2014-01096
`
`Patent 7,537,370
`_______________
`
`PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION OF JAMIE
`B. BEABER PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`
`
`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`
`
`Case IPR2014-01096
`Patent No. 7,537,370
`Petitioner’s Motion for Pro Hac Vice Admission
`
`
`PETITIONER’S EXHIBIT LIST
`
`Description
`
`Exhibit #
`
`Previously Filed
`U.S. Patent No. 7,537,370
`Prosecution History of U.S. Patent No. 7,537,370
`Complaints filed in Related District Court Cases
`Declaration of Michael J. Escuti, Ph.D. (“Escuti Decl.”)
`U.S. Patent No. 5,461,547 (“Ciupke”)
`U.S. Patent No. 5,005,108 (“Pristash”)
`EP500960 (“Ohe”)
`U.S. Patent No. 5,408,388 (“Kobayashi”)
`U.S. Patent No. 5,160,195 (“Miller”)
`J. A. Castellano, Handbook of Display Technology, Academic Press Inc., San
`Diego, 1992, at pp. 9-13 and Ch. 8
`U.S. Patent No. 5,598,280 (“Nishio”)
`U.S. Patent No. 5,384,658 (“Ohtake”)
`U.S. Patent No. 5,303,322 (“Winston”)
`U.S. Patent No. 5,050,946 (“Hathaway”)
`U.S. Patent No. 5,828,488 (“Ouderkirk”)
`3M product brochure 75-0500-0403-7, “Brightness Enhancement Film
`(BEF),” 2 pages (1993)
`U.S. Patent No. 5,706,134 (“Konno”)
`U.S. Patent No. 5,944,405 (“Takeuchi”)
`Currently Filed
`Declaration of Jamie B. Beaber in Support of Motion for Pro Hac Vice
`Admission
`
`
`1001
`1002
`1003
`1004
`1005
`1006
`1007
`1008
`1009
`1010
`
`1011
`1012
`1013
`1014
`1015
`1016
`
`1017
`1018
`
`1019
`
`Pursuant to 37 C.F.R. § 42.10(c) and in response to the authorization provided
`
`by the United States Patent and Trademark Office’s Patent Trial and Appeal Board
`
`(“Board”) in the Notice of Filing Date Accorded to Petition (Paper Number 3,
`
`entered July 16, 2014) (“Notice”), Petitioner LG Display Co., Ltd. (“Petitioner”)
`
`hereby files this motion for Jamie B. Beaber to appear pro hac vice on its behalf, as
`
`1
`
`
`
`Case IPR2014-01096
`Patent No. 7,537,370
`Petitioner’s Motion for Pro Hac Vice Admission
`
`back-up counsel, before the Board in IPR2014-01096.1 This motion follows the
`
`guidelines set forth in IPR2013-00639, Paper 7, entered October 15, 2013 (“Order”).
`
`I.
`
`TIME FOR FILING
`
`Pursuant to the Order, this motion for pro hac vice admission is being filed no
`
`sooner than twenty-one (21) days after service of the petition.
`
`II.
`
`STATEMENT OF FACTS
`
`Pursuant to the Order, the following statement of facts shows that there is
`
`good cause for the Board to recognize Mr. Beaber pro hac vice.
`
`Lead counsel for this proceeding, Robert G. Pluta, is a registered practitioner
`
`(Registration No. 50,970).
`
`Mr. Beaber is an experienced litigation attorney, and has been involved in
`
`numerous patent infringement cases in the U.S. International Trade Commission and
`
`in federal District Courts across the country. He has experience in various aspects of
`
`patent infringement matters including trials, Markman hearings, and summary
`
`judgment hearings. Mr. Beaber is a member in good standing of the District of
`
`Columbia Bar and the Michigan Bar, and is admitted to practice before the United
`
`
`1 Corresponding motions for Pro Hac Vice admission are being concurrently filed in
`
`co-pending cases IPR2014-01092, IPR2014-01094, IPR2014-01095, IPR2014-01097,
`
`IPR2014-01357, IPR2014-01359, and IPR2014-01362.
`
`2
`
`
`
`Case IPR2014-01096
`Patent No. 7,537,370
`Petitioner’s Motion for Pro Hac Vice Admission
`
`States Court of Appeals for the Federal Circuit, the District of Columbia Court of
`
`Appeals, and the United States District Courts for the Eastern District of Texas and
`
`the District of Columbia. Mr. Beaber has not been suspended or disbarred from
`
`practice, never had any application for admission to practice denied, nor had any
`
`sanctions or contempt citations imposed against him.
`
`Mr. Beaber is lead counsel for the defendants, which include Petitioner, in a co-
`
`pending litigation, Delaware Display Group LLC and Innovative Display Technologies LLC v.
`
`LG Electronics, Inc., LG Electronics U.S.A., Inc., LG Display Co., Ltd., and LG Display
`
`America, Inc., Case No. 1:13-cv-02109, pending in the United States District Court for
`
`the District of Delaware. That litigation involves U.S. Patent No. 7,537,370 (“the ’370
`
`Patent”), the same patent at issue in this proceeding, as well as several other patents in
`
`the same family as the ’370 Patent. In his role as lead counsel in the co-pending
`
`litigation, Mr. Beaber has reviewed and is familiar with the ’370 Patent and related
`
`patents, the asserted prior art references, and invalidity claim charts. Further, Mr.
`
`Beaber has been involved and is familiar with the factual and legal arguments at issue
`
`3
`
`
`
`Case IPR2014-01096
`Patent No. 7,537,370
`Petitioner’s Motion for Pro Hac Vice Admission
`
`in that case. As such, Mr. Beaber has established familiarity with the subject matter at
`
`issue in this proceeding.2
`
`Mr. Beaber has read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.,
`
`and he agrees to be subject to the USPTO Rules of Professional Conduct set forth in
`
`37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`Mr. Beaber is concurrently applying to appear pro hac vice in IPR2014-01092, IPR2014-
`
`01094, IPR2014-01095, IPR2014-01097, IPR2014-01357, IPR2014-01359, and
`
`IPR2014-01362. Mr. Beaber has not applied to appear pro hac vice before the Board in
`
`connection with any other proceedings in the last three years.
`
`Petitioner has expended significant financial resources in the co-pending
`
`litigation with Mr. Beaber as counsel, and Petitioner wishes to continue using Mr.
`
`Beaber in this proceeding.
`
`
`2 Mr. Beaber also entered an appearance as counsel for third parties Dell Inc. in Case
`
`No. 2:13-cv-00523 (E.D. Tex.) on September 5, 2014 and Hewlett-Packard Company
`
`in Case No. 2:13-cv-00524 (E.D. Tex.) on October 8, 2014. Each of these cases
`
`involve the ’370 Patent and related patents. Although these cases do not involve
`
`Petitioner, Mr. Beaber’s role in these cases further underscores his familiarity with the
`
`subject matter at issue in this proceeding.
`
`4
`
`
`
`Case IPR2014-01096
`Patent No. 7,537,370
`Petitioner’s Motion for Pro Hac Vice Admission
`
`
`As such, Petitioner respectfully submits that there is good cause for the Board
`
`to recognize Mr. Beaber as counsel pro hac vice during this proceeding.
`
`III. AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
`
`This Motion for pro hac vice admission is accompanied by a Declaration of Mr.
`
`Beaber as required by the Order (Ex. 1019).
`
`Dated: December 3, 2014
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Robert G Pluta Reg No 50970/
`Robert G. Pluta
`Registration No. 50,970
`MAYER BROWN LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`Telephone: 312-701-8641
`Facsimile: 312-701-7711
`rpluta@mayerbrown.com
`
`
`Counsel for LG Display Co., Ltd.
`
`5
`
`
`
`Case IPR2014-01096
`Patent No. 7,537,370
`Petitioner’s Motion for Pro Hac Vice Admission
`
`
`CERTIFICATE OF SERVICE
`
`I hereby certify that on this 3rd day of December, 2014, a copy of the
`
`attached PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION OF
`
`JAMIE B. BEABER PURSUANT TO 37 C.F.R. § 42.10(c), together with the
`
`supporting declaration of Jamie B. Beaber, was served by e-mail pursuant to Patent
`
`Owner’s consent in its Mandatory Notices Pursuant to 37 C.F.R. §§ 42.8(a)(2) and
`
`42.8(b): jkimble@bcpc-law.com and jbragalone@bcpc-law.com.
`
`
`
` Respectfully submitted,
`
`Date: December 3, 2014 By:
`
`
`/Robert G Pluta Reg No 50970/
`Robert G. Pluta
`Registration No. 50,970
`Mayer Brown LLP
`71 S. Wacker Drive
`Chicago, IL 60606
`Telephone: 312-701-8641
`Facsimile:
`312-701-7711
`
`Counsel for LG Display Co., Ltd.
`
`
`
`1
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
