`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`LG DISPLAY CO., LTD.
`Petitioner
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`v.
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`INNOVATIVE DISPLAY TECHNOLOGIES LLC
`Patent Owner
`_______________
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`Case: IPR2014-01362
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`Patent 7,384,177
`_______________
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`
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`PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION OF JAMIE
`B. BEABER PURSUANT TO 37 C.F.R. § 42.10(c)
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`
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`Mail Stop Patent Board
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`
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`Case IPR2014-01362
`Patent No. 7,384,177
`Petitioner’s Motion for Pro Hac Vice Admission
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`PETITIONER’S EXHIBIT LIST
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`Description
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`Exhibit #
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`Previously Filed
`U.S. Patent No. 7,384,177
`Prosecution History of U.S. Patent No. 7,384,177
`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. 5,054,885 (“Melby”)
`U.S. Patent No. 5,453,855 (“Nakamura”)
`U.S. Patent No. 4,142,781 (“Baur”)
`U.S. Patent No. 5,432,626 (“Sasuga”)
`U.S. Patent No. 5,005,108 (“Pristash”)
`U.S. Patent No. 5,567,042 (“Farchmin”)
`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”)
`European Patent Application Publication No. EP500960 (“Ohe”)
`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”)
`U.S. Patent No. 5,381,309 (“Borchardt”)
`Currently Filed
`Declaration of Jamie B. Beaber in Support of Motion for Pro Hac Vice
`Admission
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`
`1001
`1002
`1003
`1004
`1005
`1006
`1007
`1008
`1009
`1010
`1011
`1012
`1013
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`1014
`1015
`1016
`1017
`1018
`1019
`1020
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`1021
`1022
`1023
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`1024
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`1
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`Case IPR2014-01362
`Patent No. 7,384,177
`Petitioner’s Motion for Pro Hac Vice Admission
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`Pursuant to 37 C.F.R. § 42.10(c) and in response to the authorization provided
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`by the United States Patent and Trademark Office’s Patent Trial and Appeal Board
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`(“Board”) in the Notice of Filing Date Accorded to Petition (Paper Number 3,
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`entered September 4, 2014) (“Notice”), Petitioner LG Display Co., Ltd. (“Petitioner”)
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`hereby files this motion for Jamie B. Beaber to appear pro hac vice on its behalf, as
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`back-up counsel, before the Board in IPR2014-01362. 1 This motion follows the
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`guidelines set forth in IPR2013-00639, Paper 7, entered October 15, 2013 (“Order”).
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`I.
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`TIME FOR FILING
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`Pursuant to the Order, this motion for pro hac vice admission is being filed no
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`sooner than twenty-one (21) days after service of the petition.
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`II.
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`STATEMENT OF FACTS
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`Pursuant to the Order, the following statement of facts shows that there is
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`good cause for the Board to recognize Mr. Beaber pro hac vice.
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`Lead counsel for this proceeding, Robert G. Pluta, is a registered practitioner
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`(Registration No. 50,970).
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`Mr. Beaber is an experienced litigation attorney, and has been involved in
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`numerous patent infringement cases in the U.S. International Trade Commission and
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`1 Corresponding motions for pro hac vice admission are being concurrently filed in co-
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`pending cases IPR2014-01092, IPR2014-01094, IPR2014-01095, IPR2014-01096,
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`IPR2014-01097, IPR2014-01357, and IPR2014-01359.
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`2
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`
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`Case IPR2014-01362
`Patent No. 7,384,177
`Petitioner’s Motion for Pro Hac Vice Admission
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`in federal District Courts across the country. He has experience in various aspects of
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`patent infringement matters including trials, Markman hearings, and summary
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`judgment hearings. Mr. Beaber is a member in good standing of the District of
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`Columbia Bar and the Michigan Bar, and is admitted to practice before the United
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`States Court of Appeals for the Federal Circuit, the District of Columbia Court of
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`Appeals, and the United States District Courts for the Eastern District of Texas and
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`the District of Columbia. Mr. Beaber has not been suspended or disbarred from
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`practice, never had any application for admission to practice denied, nor had any
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`sanctions or contempt citations imposed against him.
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`Mr. Beaber is lead counsel for the defendants, which include Petitioner, in a co-
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`pending litigation, Delaware Display Group LLC and Innovative Display Technologies LLC v.
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`LG Electronics, Inc., LG Electronics U.S.A., Inc., LG Display Co., Ltd., and LG Display
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`America, Inc., Case No. 1:13-cv-02109, pending in the United States District Court for
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`the District of Delaware. That litigation involves U.S. Patent No. 7,384,177 (“the ’177
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`Patent”), the same patent at issue in this proceeding, as well as several other patents in
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`the same family as the ’177 Patent. In his role as lead counsel in the co-pending
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`litigation, Mr. Beaber has reviewed and is familiar with the ’177 Patent and related
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`patents, the asserted prior art references, and invalidity claim charts. Further, Mr.
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`Beaber has been involved and is familiar with the factual and legal arguments at issue
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`3
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`
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`Case IPR2014-01362
`Patent No. 7,384,177
`Petitioner’s Motion for Pro Hac Vice Admission
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`in that case. As such, Mr. Beaber has established familiarity with the subject matter at
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`issue in this proceeding.2
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`Mr. Beaber has read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.,
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`and he agrees to be subject to the USPTO Rules of Professional Conduct set forth in
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`37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`Mr. Beaber is concurrently applying to appear pro hac vice in IPR2014-01092, IPR2014-
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`01094, IPR2014-01095, IPR2014-01096, IPR2014-01097, IPR2014-01357, and
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`IPR2014-01359. Mr. Beaber has not applied to appear pro hac vice before the Board in
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`connection with any other proceedings in the last three years.
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`2 Mr. Beaber also entered an appearance as counsel for third parties Dell Inc. in Case
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`No. 2:13-cv-00523 (E.D. Tex.) on September 5, 2014, Hewlett-Packard Company in
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`Case No. 2:13-cv-00524 (E.D. Tex.) on October 8, 2014, and Hyundai Motor
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`Company, Hyundai Motor America, Hyundai Motor Manufacturing Alabama, LLC,
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`Kia Motors Corporation, Kia Motors America, Inc., and Kia Motors Manufacturing
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`Georgia, Inc. in Case No. 2:14-cv-00201 (E.D. Tex.) on July 9, 2014. Each of these
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`cases involve the ’177 Patent and related patents. Although these cases do not
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`involve Petitioner, Mr. Beaber’s role in these cases further underscores his familiarity
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`with the subject matter at issue in this proceeding.
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`4
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`
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`Case IPR2014-01362
`Patent No. 7,384,177
`Petitioner’s Motion for Pro Hac Vice Admission
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`Petitioner has expended significant financial resources in the co-pending
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`litigation with Mr. Beaber as counsel, and Petitioner wishes to continue using Mr.
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`Beaber in this proceeding.
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`As such, Petitioner respectfully submits that there is good cause for the Board
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`to recognize Mr. Beaber as counsel pro hac vice during this proceeding.
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`III. AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
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`This Motion for pro hac vice admission is accompanied by a Declaration of Mr.
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`Beaber as required by the Order (Ex. 1024).
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`Dated: December 3, 2014
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`Respectfully submitted,
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`/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.
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`5
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`
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`Case IPR2014-01362
`Patent No. 7,384,177
`Petitioner’s Motion for Pro Hac Vice Admission
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`CERTIFICATE OF SERVICE
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`I hereby certify that on this 3rd day of December, 2014, a copy of the
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`attached PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION OF
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`JAMIE B. BEABER PURSUANT TO 37 C.F.R. § 42.10(c), together with the
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`supporting declaration of Jamie B. Beaber, was served by e-mail pursuant to Patent
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`Owner’s consent in its Mandatory Notices Pursuant to 37 C.F.R. §§ 42.8(a)(2) and
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`42.8(b): jkimble@bcpc-law.com and jbragalone@bcpc-law.com.
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` Respectfully submitted,
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`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