Filed on behalf of Innovative Display Technologies LLC
`By:
`Justin B. Kimble (jkimble@bcpc-law.com)
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`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
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`Bragalone Conroy P.C.
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`2200 Ross Ave.
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`Suite 4500 – West
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`Dallas, TX 75201
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`Tel: 214.785.6670
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`Fax: 214.786.6680
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`
`
`
`LG DISPLAY, LTD.
`Petitioner
`v.
`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`Patent Owner
`
`
`Case IPR2014-01097
`U.S. Patent No. 7,300,194
`
`
`
`
`PRO HAC VICE MOTION TO ADMIT ATTORNEY JEFFREY R. BRAGALONE
`PURSUANT TO 37 C.F.R. § 42.10(c)
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`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`
`
`By:
`Justin B. Kimble (jkimble@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`
`Bragalone Conroy P.C.
`
`2200 Ross Ave.
`
`Suite 4500 – West
`
`Dallas, TX 75201
`
`Tel: 214.785.6670
`
`Fax: 214.786.6680
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`LG DISPLAY, LTD.
`Petitioner
`v.
`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`Patent Owner
`
`
`Case IPR2014-01097
`U.S. Patent No. 7,300,194
`
`
`
`
`PRO HAC VICE MOTION TO ADMIT ATTORNEY JEFFREY R. BRAGALONE
`PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`
`
`
`Case IPR2014-01097
`Patent 7,300,194
`
`
`
`Patent owner Innovative Display Technologies LLC (“IDT”) hereby files this motion
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`pursuant to 37 C.F.R. § 42.10(c) for Jeffrey R. Bragalone to appear pro hac vice on its behalf
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`before the Patent Trial and Appeal Board in IPR2014-01097. This motion follows the guidelines
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`set forth in IPR2013-00639, Paper 7, entered October 15, 2013.
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`A. Lead Counsel is a Registered Practitioner.
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`IDT has already designated a registered practitioner, Justin B. Kimble (reg. no. 58,591) as
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`lead counsel. IDT intends to designate Jeffrey R. Bragalone as its back-up counsel in the event this
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`motion is granted.
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`B. There is Good Cause for the Board to Recognize Jeffrey R. Bragalone pro hac vice
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`during this proceeding.
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`1. Mr. Bragalone is an experienced litigator.
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`Jeffrey R. Bragalone is an experienced litigator with over 26 years of experience. He has
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`argued three patent cases before the Federal Circuit: (1) Greenliant Sys., Inc. v. Xicor LLC, 692
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`F.3d 1261 (Fed. Cir. 2012); (2) United Access Technologies, LLC v. Earthlink, Inc., 432 F. App’x
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`976 (Fed. Cir. 2011); (3) Board of Regents of the University of Texas System v. BenQ America
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`Corp., 533 F.3d 1362 (Fed. Cir. 2008); and appeared on brief in a fourth case: (4) Tegic Commc’ns
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`Corp. v. Board of Regents of the University of Texas System, 458 F.3d 1335 (Fed. Cir. 2006). In
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`addition to his argument before the Federal Circuit, Mr. Bragalone has represented numerous
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`clients in patent litigation and general litigation as lead counsel in district courts and state courts
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`across the United States. He is presently representing the defendant in Texas Advanced
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`Optoelectronic Solutions, Inc. v. Intersil Corp., No. 4:08-cv-451 (E.D. Tex., filed Nov. 25, 2008),
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`which is set for trial this December. Mr. Bragalone also currently represents plaintiffs in the patent
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`2
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`Case IPR2014-01097
`Patent 7,300,194
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`litigation styled HSM Portfolio LLC et al. v. Fujitsu Ltd. et, No. 1:11-cv-00770 (D. Del., filed
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`September 1, 2011).
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`2. Mr. Bragalone has an established familiarity with the subject matter at issue
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`in the proceeding.
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`Mr. Bragalone currently represents IDT in its assertion of U.S. Patent No. 7,300,194 and
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`its related patents in numerous cases pending in the District of Delaware and the Eastern District
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`of Texas. See, e.g., Innovative Display Technologies LLC v. Acer Inc. et al., No. 2:13-cv-00522
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`(E.D. Tex., filed June 28, 2013); see also Delaware Display Group LLC et al. v. Sony Corp et al.,
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`No. 1:13-cv-02111 (D. Del., filed Dec. 31, 2013). As lead counsel in those actions, Mr. Bragalone
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`has familiarized himself with the subject matter at issue in this proceeding, i.e., light emitting panel
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`assemblies. During the course of those lawsuits, Mr. Bragalone has developed invalidity defenses
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`for the patent-at-issue in this petition as well as its related patents, all of which concern light
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`emitting panel assemblies. Furthermore, in those lawsuits Mr. Bragalone has developed
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`infringement allegations that assert the patent-at-issue in this petition against various light emitting
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`panel assemblies, including those found in smart phones, tablets, laptop computers, and televisions
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`to name a few. In his role as the lead counsel in those litigations, Mr. Bragalone has spent
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`significant time learning the technology involved in light emitting panel assemblies such as those
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`found in the patent-at-issue in this proceeding.
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`C. Mr. Bragalone has Submitted Herewith a Declaration1 Attesting the Following
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`Facts.
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`1.
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`Mr. Bragalone is a member in good standing of the Texas State Bar.
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`1 See Declaration of Jeffrey R. Bragalone, attached hereto as Exhibit 2001.
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`
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`3
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`
`
`Case IPR2014-01097
`Patent 7,300,194
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`2.
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`Mr. Bragalone has never been subject to any suspensions or disbarments from
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`practice before any court or administrative body.
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`3.
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`None of Mr. Bragalone’s applications for admission to practice before any court or
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`administrative body has ever been denied.
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`4.
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`Mr. Bragalone has never been sanctioned nor had contempt citations imposed by
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`any court or administrative body.
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`5.
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`Mr. Bragalone has read and will comply with the Office Patent Trial Practice Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`6.
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`Mr. Bragalone will be subject to the USPTO Rules of Professional Conduct set
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`forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R.
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`§ 11.19(a).
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`7.
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`During the past three years, Mr. Bragalone has applied to appear pro hac vice before
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`the Office in the proceedings IPR2014-00785, IPR2014-00810, IPR2014-00824,
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`and IPR2014-00825 on behalf of the patent owner in those matters, Securus
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`Technologies, Inc. Mr. Bragalone has also applied to appear pro hac vice before
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`the Office in the following proceedings: IPR2014-01092, IPR2014-01094,
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`IPR2014-01095, and IPR2014-01096, the motions for which are filed concurrently
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`with this motion. All of those proceedings involve the same Petitioner and Patent
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`Owner as this proceeding as well as patents related to the patent-at-issue in this
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`proceeding. Each of the pro hac vice motions discussed in this paragraph is
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`currently pending.
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`8.
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`Mr. Bragalone has familiarity with the subject matter at issue in the proceeding as
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`set forth in Section B.2 above.
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`
`
`4
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`
`
`Case IPR2014-01097
`Patent 7,300,194
`
`Dated: August 11, 2014
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`Respectfully submitted,
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`
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`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`
`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that this document has been served via electronic mail on
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`August 11, 2014, to Petitioner at following email addresses pursuant to its consent in its Petition
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`at p. 4.
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`rpluta@mayerbrown.com; bpaul@mayerbrown.com; astreff@mayerbrown.com;
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`alam@mayerbrown.com; and DDGIPR@mayerbrown.com.
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`_____________________________
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`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
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`5
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