Filed on behalf of Intellectual Ventures II LLC
`By: Herbert D. Hart III
`Sharon A. Hwang
`McAndrews, Held & Malloy, Ltd.
`500 W. Madison St., 34th Floor
`Chicago, IL 60661
`Tel: 312-775-8000
`Fax: 312-775-8100
`E-mail:
`hhart@mcandrews-ip.com
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`ERICSSON INC. and
`
`TELEFONAKTIEBOLAGET LM ERICSSON
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES II LLC
`Patent Owner
`_____________
`
`Case IPR2014-01195
`Patent No. 7,787,431
`_____________
`
`PATENT OWNER MOTION FOR ADMISSION
`PRO HAC VICE OF RAJENDRA A. CHIPLUNKAR
`
`
`By: Herbert D. Hart III
`Sharon A. Hwang
`McAndrews, Held & Malloy, Ltd.
`500 W. Madison St., 34th Floor
`Chicago, IL 60661
`Tel: 312-775-8000
`Fax: 312-775-8100
`E-mail:
`hhart@mcandrews-ip.com
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`ERICSSON INC. and
`
`TELEFONAKTIEBOLAGET LM ERICSSON
`Petitioner
`
`v.
`
`INTELLECTUAL VENTURES II LLC
`Patent Owner
`_____________
`
`Case IPR2014-01195
`Patent No. 7,787,431
`_____________
`
`PATENT OWNER MOTION FOR ADMISSION
`PRO HAC VICE OF RAJENDRA A. CHIPLUNKAR
`
`
`
`IPR2014-01195
`Patent Owner Motion for Admission Pro Hac Vice of Rajendra Chiplunkar
`
`I.
`
`Statement Of Precise Relief Requested
`
`
`
`Pursuant to 37 C.F.R. § 42.10(c) and Paper No. 3 authorizing the parties to
`
`file motions for pro hac vice admission under 37 C.F.R. § 42.10(c), Patent Owner
`
`requests that the Patent Trial and Appeal Board (“Board”) admit Rajendra A.
`
`Chiplunkar (“Mr. Chiplunkar”) pro hac vice in this proceeding, IPR2014-01195.
`
`This motion is filed in accordance with the “Order Authorizing Motion for Pro
`
`Hac Vice Admission” in Case IPR2013-00639, Paper 7.
`
`Counsel for Petitioner has stated that Petitioner will not oppose this motion
`
`for admission pro hac vice of Mr. Chiplunkar.
`
`II. Time for Filing
`
`
`
`This Motion is being filed no sooner than twenty one (21) days after service
`
`of the Petition.
`
`III. Statement of Facts Showing Good Cause for the Board to Recognize
`Counsel Pro Hac Vice During the Proceeding
`
`
`
`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel
`
`pro hac vice during a proceeding upon a showing of good cause, “subject to the
`
`condition that lead counsel be a registered practitioner and to any other conditions
`
`as the Board may impose.” Section 42.10(c) further states that “where the lead
`
`counsel is a registered practitioner, a motion to appear pro hac vice by counsel who
`
`is not a registered practitioner may be granted upon showing that counsel is an
`
`
`
`1
`
`
`
`IPR2014-01195
`Patent Owner Motion for Admission Pro Hac Vice of Rajendra Chiplunkar
`
`
`experienced litigating attorney and has an established familiarity with the subject
`
`matter at issue in the proceeding.” The facts here establish good cause for the
`
`Board to recognize Rajendra A. Chiplunkar pro hac vice in this proceeding.
`
`1.
`
`Lead counsel, Herbert D. Hart III, is a registered practitioner. Backup
`
`counsel, Sharon A. Hwang is also a registered practitioner.
`
`2. Mr. Chiplunkar is an associate at the law firm of McAndrews, Held
`
`and Malloy, Ltd., is a litigation attorney, and is currently involved in lawsuits
`
`involving patent infringement in District Courts across the country. Mr.
`
`Chiplunkar is a member of the Illinois bar in good standing, is admitted to practice
`
`in the U.S. District Court for the Northern District of Illinois and has also been
`
`admitted to practice pro hac vice in other Federal District courts. Mr. Chiplunkar
`
`has experience in fact and expert document and deposition discovery and motion
`
`practice before U.S. District Courts in connection with patent infringement
`
`litigation matters.
`
`3.
`
`Prior to entering the field of law, Mr. Chiplunkar was employed with
`
`Motorola Inc. for over ten years as an electrical engineer. At Motorola, Mr.
`
`Chiplunkar contributed to the design of telecommunications equipment. Through
`
`his work at Motorola Inc., Mr. Chiplunkar gained valuable experience in the
`
`technologies relevant to the challenged Patent and the alleged prior art references.
`
`
`
`2
`
`
`
`IPR2014-01195
`Patent Owner Motion for Admission Pro Hac Vice of Rajendra Chiplunkar
`
`
`4. Mr. Chiplunkar has spent substantial time reviewing and analyzing the
`
`patent at issue in this proceeding, its file history, the Petition, the references cited,
`
`and the Declarations of Dr. Haas, the Petitioner’s Expert. Mr. Chiplunkar is
`
`familiar with the invalidity arguments advanced by the Petitioner. Additionally,
`
`Mr. Chiplunkar substantively contributed to the Patent Owner Response filed in
`
`this proceeding. Further, Mr. Chiplunkar has attended the cross-examination of
`
`Petitioner’s Expert Declarant, Dr. Haas and the cross-examination of Patent
`
`Owner’s Expert Declarant, Dr. Zeger.
`
`5.
`
`Therefore, Patent Owner respectfully submits that there is good cause
`
`for the Board to recognize Mr. Chiplunkar as counsel Pro Hac Vice during this
`
`proceeding.
`
`IV. Affidavit or Declaration of Individuals Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is accompanied by the Declaration
`
`of Mr. Rajendra A. Chiplunkar (Ex. 2005) as required by the Order Authorizing
`
`Motion for Pro Hac Vice Admission.
`
`
`
`
`
`
`Dated: August 6, 2015
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`
`
`
`/Herbert D. Hart III/
`Herbert D. Hart III
`Registration No. 30,063
`McAndrews, Held & Malloy, Ltd.
`500 West Madison Street, 34th Floor
`Chicago, Illinois 60661
`
`
`
`3
`
`
`
`IPR2014-01195
`Patent Owner Motion for Admission Pro Hac Vice of Rajendra Chiplunkar
`
`Office: (312) 775-8000
`Fax: (312) 775-8100
`Email: hhart@mcandrews-ip.com
`
`Lead Counsel for Patent Owner
`
`
`
`
`
`4
`
`
`
`IPR2014-01195
`Patent Owner Motion for Admission Pro Hac Vice of Rajendra Chiplunkar
`
`CERTIFICATE OF SERVICE
`
`
`
`I hereby certify that on August 6, 2015 a true and correct copy of the
`
`following materials:
`
` Patent Owner Motion For Admission Pro Hac Vice Of Rajendra A.
`
`Chiplunkar
`
`was served via email to counsel for Petitioner at the following:
`
`J. Andrew Lowes (Lead Counsel)
`David M. O’Dell (Back-up Counsel)
`HAYNES AND BOONE, LLP
`andrew.lowes.ipr@haynesboone.com
`david.odell.ipr@haynesboone.com
`
`
`
`Date: August 6, 2015
`
`
`
`
`
`
`
`
`
`/Herbert D. Hart III/
`Herbert D. Hart III
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