Paper No.
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`CISCO SYSTEMS, INC. and QUANTUM CORPORATION,
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.,
`Patent Owner.
`________________
`
`Case IPR2014-01544
`Patent 7,051,147
`
`________________
`
`PETITIONERS’ UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION PURSUANT TO 37 C.F.R. § 42.10(C)
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`________________
`
`CISCO SYSTEMS, INC. and QUANTUM CORPORATION,
`Petitioners,
`
`v.
`
`CROSSROADS SYSTEMS, INC.,
`Patent Owner.
`________________
`
`Case IPR2014-01544
`Patent 7,051,147
`
`________________
`
`PETITIONERS’ UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION PURSUANT TO 37 C.F.R. § 42.10(C)
`
`
`
`Petitioners’ Motion for Pro Hac Vice Admission
`
`IPR2014-01544
`U.S. Patent No. 7,051,147
`
`Petitioners Cisco Systems, Inc. and Quantum Corporation respectfully move
`
`that the Board recognize Mr. Matthew C. Gaudet as counsel pro hac vice during
`
`this proceeding. Patent Owner does not oppose this motion.
`
`1. Time for Filing
`
`This Motion for Pro Hac Vice Admission is being filed no sooner than
`
`twenty one (21) days after service of the petition.
`
`2. Statement of Facts Showing Good Cause for Counsel Pro Hac Vice
`
`Petitioners have been authorized to file motions seeking admission pro hac
`
`vice under 37 C.F.R. 42.10(c). (Paper No. 4 at 2). Petitioners’ lead and back-up
`
`counsel are registered practitioners:
`
`Lead Counsel:
`
`David L. McCombs, USPTO Reg. No. 32,271;
`
`Backup Counsel: Andrew S. Ehmke, USPTO Reg. No. 50,271
`
`Scott T. Jarratt, USPTO Reg. No. 70,297.
`
`The following statement of facts shows that there is good cause for the
`
`Board to recognize Mr. Gaudet pro hac vice on behalf of the Petitioners.
`
`In summary, Mr. Gaudet is an experienced litigator, has established
`
`familiarity with the subject matter at issue in this proceeding from his participation
`
`in co-pending litigation involving the subject patent, and if admitted, will be
`
`involved in the depositions that occur in this proceeding. Specifically, U.S. Patent
`
`No. 7,051,147 is currently asserted against Petitioner Cisco Systems, Inc. in a co-
`
`–1–
`
`
`
`Petitioners’ Motion for Pro Hac Vice Admission
`
`IPR2014-01544
`U.S. Patent No. 7,051,147
`
`pending litigation, Crossroads Systems, Inc. v. Cisco Systems, Inc., 1:14-cv-00148-
`
`SS (W.D. Tex.) (“the co-pending litigation”). Mr. Gaudet is a member of the
`
`Georgia bar in good standing, and is representing Cisco Systems, Inc. in the co-
`
`pending litigation.
`
`Mr. Gaudet has analyzed prior art references and claim charts in connection
`
`with invalidity contentions and has been involved in forming claim construction
`
`positions related to the claimed inventions, all of which are relevant to the petition
`
`requesting inter partes review of U.S. Patent No. 7,051,147. Petitioners wish to
`
`apply Mr. Gaudet’s knowledge of the patent by employing him as counsel in this
`
`proceeding. Admission of Mr. Gaudet pro hac vice will enable the Petitioners to
`
`avoid unnecessary expense and duplication of work between this proceeding and
`
`the co-pending litigation.
`
`Petitioners’ lead and backup counsel are registered practitioners and Mr.
`
`Gaudet is an experienced litigation attorney having familiarity with the subject
`
`matter at issue in this proceeding. Therefore, Petitioners respectfully submit that
`
`there is good cause for the Board to recognize Mr. Gaudet as counsel pro hac vice
`
`during this proceeding.
`
`–2–
`
`
`
`Petitioners’ Motion for Pro Hac Vice Admission
`
`IPR2014-01544
`U.S. Patent No. 7,051,147
`
`3. Affidavit of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is supported by an Affidavit of
`
`Mr. Gaudet (CQ-1015).
`
`Date: May 13, 2015
`
`Respectfully submitted,
`
`/Scott T. Jarratt/
`By:
`Scott T. Jarratt
`USPTO Reg. No. 70,297
`Counsel for Petitioners
`
`–3–
`
`
`
`IPR2014-01544
`U.S. Patent No. 7,051,147
`
`PETITIONERS’ EXHIBIT LIST
`
`May 13, 2015
`
`CQ-1008
`
`CQ-1001 U.S. Patent No. 7,051,147
`CQ-1002
`Prosecution History of U.S. Patent No. 7,051,147
`CQ-1003 Declaration of Andrew Hospodor Under 37 C.F.R. § 1.68
`CQ-1004 CMD Technology, Inc., CRD-5500 SCSI Raid Controller User's
`Manual, Revision 1.3, November 21, 1996
`CQ-1005 CMD Technology CRD-5500 RAID,
`http://web.archive.org/web/19961226091552/http://www.cmd.com/br
`ochure/crd5500.htm, archived December 26, 1996 by archive.org
`CQ-1006 Hewlett-Packard Journal, Volume 47, Number 5, October 1996
`Sun Microsystems Computer Company, SPARCstorage Array
`CQ-1007
`Configuration Guide, Revision A, March 1995 (“SPARCstorage
`Guide”)
`SPARCstorage Array – Product Brief,
`http://web.archive.org/web/19961220045017/http://www.sun.com/pro
`ducts-n-solutions/hw/peripherals/array.html, archived December 20,
`1996 by archive.org (“SPARCstorage Product Brief”)
`CQ-1009 ORDER of November 8, 2011, Crossroads Systems, Inc. v. 3PAR,
`Inc., et. al., case no. 1-10-cv-00652 (W.D. Tex. 2010)
`CQ-1010 American National Standard of Accredited Standards Committee X3,
`Small Computer System Interface – 2 (X3T9.2), Rev. 10L, September
`7, 1993
`CQ-1011 American National Standard for Information Systems, Fibre Channel
`Physical and Signaling Interface (FC-PH) X3.230, Rev. 4.3, June 1,
`1994
`CQ-1012 HP Journal Online - Home, available at
`http://www.hpl.hp.com/hpjournal/journal.html, accessed July 31,
`2014
`CQ-1013 Affidavit of Clement S. Roberts In Support of Petitioners’ Unopposed
`Motion for Pro Hac Vice Admission
`CQ-1014 Declaration of Jodi L. Gregory (unfiled)
`
`–1–
`
`
`
`Petitioners’ Motion for Pro Hac Vice Admission
`
`IPR2014-01544
`U.S. Patent No. 7,051,147
`
`CQ-1015 Affidavit of Matthew C. Gaudet In Support of Petitioners’ Unopposed
`Motion for Pro Hac Vice Admission
`
`–2–
`
`
`
`Petitioners’ Motion for Pro Hac Vice Admission
`
`IPR2014-01544
`U.S. Patent No. 7,051,147
`
`CERTIFICATE OF SERVICE
`
`The undersigned certifies, in accordance with 37 C.F.R. § 42.6(e), that
`
`service was made on the Patent Owner as detailed below.
`
`Date of service May 13, 2015
`
`Manner of service Federal Express
`
`Documents served Petitioners’ Unopposed Motion For Pro Hac Vice Admission
`Pursuant To 37 C.F.R. § 42.10(c)
`Petitioners’ Exhibit List of May 13, 2015
`Exhibit CQ-1015
`Persons served Steven R. Sprinkle
`Russell Wong
`John L. Adair
`James Hall
`
`Sprinkle IP Law Group
`ATTN: Crossroads IPR
`1301 W. 25th Street, Suite 408
`Austin, TX 78705
`
`/Scott T. Jarratt/
`Scott T. Jarratt
`USPTO Reg. No. 70,297
`Counsel for Petitioners
`
`
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