`___________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
`
`UNIFIED PATENTS INC.
`Petitioner
`
`v.
`
`DRAGON INTELLECTUAL PROPERTY, LLC
`Patent Owner
`___________
`
`Case IPR2014-01252
`Patent 5,930,444
`
`
`
`
`
`Before GREGG I. ANDERSON, STACEY G. WHITE, and J. JOHN LEE,
`Administrative Patent Judges.
`
`WHITE, Administrative Patent Judge.
`
`MOTION TO WITHDRAW AS COUNSEL
`PURSUANT TO 37 C.R.F. 42.10(E)
`
`
`
`
`
`
`
`
`
`
`
`I.
`
`Statement of Precise Relief Requested
`
`Pursuant to 37 C.F.R. § 42.10 and authorization provided by the Patent Trial
`
`and Appeal Board (“the Board”) on November 10, 2015, Patent Owner Dragon
`
`Intellectual Property, LLC (“Dragon”) respectfully requests that the Board
`
`authorize withdrawal of its current counsel Jason S. Angell and Robert E. Freitas
`
`of Freitas Angell & Weinberg LLP.
`
`II.
`
`Statement of Facts Showing Good Cause for the Board to Authorize
`Withdrawal of Counsel
`
`On August 26, 2015, Patent Owner Dragon appointed Jason S. Angell and
`
`Robert E. Freitas as its attorneys in the above-captioned inter partes review.
`
`Patent Owner Dragon requests that current designated counsel, Jason S. Angell and
`
`Robert E. Freitas, be allowed to withdraw from the present proceeding, and new
`
`counsel, Kai Zhu, be designated lead counsel to represent Dragon in this
`
`proceeding. Dragon intends to appoint new counsel as follows:
`
`Kai Zhu (Reg. No. 64,586)
`60 Cody Ln
`Los Altos, CA 94022
`Telephone: (650) 999-0172
`Facsimile: (928) 569-1639
`kz@dragonipllc.com
`
`New counsel meets the requirements of 37 C.F.R. § 42.10(c) as lead counsel
`
`and is a registered practitioner. In addition Dragon’s proposed lead counsel has
`
`read and intends to comply with the Office Patent Trial Practice Guide and the
`
`-1-
`
`
`
`
`
`Board’s Rules of Practice for Trials, as set forth in Part 42 of the C.F.R. Dragon
`
`has advised the Board that the withdrawal and change in lead counsel will not
`
`affect the orderly progress of this proceeding.
`
`Patent Owner Dragon respectfully requests that the Board grant its motion to
`
`authorize withdrawal of counsel. Upon grant of this motion, current counsel for
`
`Dragon will promptly file an updated mandatory notice. Dragon has herewith filed
`
`a new Power of Attorney for Mr. Zhu.
`
`
`
`Dated: November 11, 2015
`
`
`
`By:/s/Jason S. Angell
`Jason S. Angell
`Reg. No. 51408
`
`
`
`
`
`-2-
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`It is certified that a copy of the foregoing has been served on Petitioner via
`
`electronic mail transmission addressed to the person(s) at the address below:
`
`Michael L. Kiklis (Reg. No. 38,939)
`Scott McKeown (Reg. No. 42,866)
`Katherine D. Cappaert (Reg. No. 71,639)
`OBLON, MCCLELLAND, MAIER & NEUSTADT, L.L.P.
`cpdocketKiklis@oblon.com
`cpdocketMcKeown@oblon.com
`cpdocketCappaert@oblon.com
`
`Jonathan Stroud
`jonathan@unifiedpatents.com
`
`Date: November 11, 2015
`
`/s/Jason S. Angell
`Jason S. Angell
`Reg. No. 51408
`
`
`
`-3-
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