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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`APPLE INC., HTC CORPORATION, HTC AMERICA, INC., SAMSUNG
`ELECTRONICS CO. LTD, SAMSUNG ELECTRONICS AMERICA, INC., AND
`AMAZON.COM, INC.
`Petitioners,
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`v.
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`MEMORY INTEGRITY, LLC
`Patent Owner
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`U.S. Patent No. 7,296,121
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`Inter Partes Review Case No. IPR2015-00163
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`PETITIONER APPLE INC.’S
`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. § 42.10(c)
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`Proceeding No.: IPR2015-00163
`Attorney Docket: 39521-0007IP4
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`Pursuant to 37 C.F.R. § 42.10(c), the Petitioner, Apple Inc. (“Apple”),
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`respectfully requests that the Board recognize Michael Rueckheim as counsel pro
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`hac vice in this proceeding. Apple seeks the counsel of Mr. Rueckheim due to his
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`experience in representing Apple in patent-related matters and particularly due to
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`his familiarity with the substantive and technical issues involved in this
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`proceeding. This motion is authorized by the Notice of Filing Date Accorded to
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`Petition that was mailed on November 10, 2014.
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`On July 21, 2015, Apple contacted counsel for the Patent Owner, Michael
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`Saunders at Farney Daniels PC, to discuss the Patent Owner’s position on this
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`motion. Mr. Saunders stated that the Patent Owner does not oppose this motion.
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`1. Statement of Facts
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`Mr. Rueckheim is a patent litigation attorney with 6 years of experience
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`representing clients in patent cases involving technologies such as memory,
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`computer architecture, wireless transmission, and software. Apple provides
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`Exhibit A, as evidence, which is Mr. Rueckheim’s biography.
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`Mr. Rueckheim has particular experience and familiarity with the
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`substantive and technical issues involved in this inter partes review proceeding.
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`Mr. Rueckheim is counsel for Apple in the co-pending litigation involving the
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`patent at issue in this proceeding, U.S. Patent. No. 7,296,121 (“the ’121 patent”):
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`2
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`Proceeding No.: IPR2015-00163
`Attorney Docket: 39521-0007IP4
`Case No. 1:13-cv-01796-GMS (Memory Integrity LLC v. Apple Inc.) in the United
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`States District Court for the District of Delaware, filed on November 1, 2013. As
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`counsel for Apple, Mr. Rueckheim is deeply involved in all aspects of the
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`litigation, including claim construction and validity analysis, and therefore has
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`established familiarity with the ’121 patent. Given Mr. Rueckheim’s experience
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`with the ’121 patent, admission of Mr. Rueckheim pro hac vice will enable Apple
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`to avoid unnecessary expense and duplication of work between this proceeding and
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`the co-pending litigation.
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`Apple will also maintain registered practitioners as lead and back-up counsel
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`as indicated in Paper No. 1 at 2: W. Karl Renner, Reg. No. 41,265 (lead counsel)
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`and Roberto Devoto, Reg. No. 55,108 (backup counsel).
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`2. Affidavit of Individual Seeking to Appear
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`This Motion for Pro Hac Vice Admission is accompanied by an Affidavit of
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`Mr. Rueckheim as required by the Order Authorizing Motion for Pro Hac Vice
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`Admission in Case IPR2013-00639 at Paper 7.
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`Accordingly, Apple submits that there is good cause under 37 C.F.R. §
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`42.10(c) for the Board to recognize Mr. Rueckheim as counsel pro hac vice during
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`this proceeding.
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`3
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`Proceeding No.: IPR2015-00163
`Attorney Docket: 39521-0007IP4
`Respectfully submitted,
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`/s/ W. Karl Renner
`W. Karl Renner
`Reg. No. 41,265
`Counsel for Petitioner Apple Inc.
`Fish & Richardson P.C.
`Telephone: (202) 783-5070
`Facsimile: (202) 783-2331
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`4
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`Date: July 21, 2015
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`Proceeding No.: IPR2015-00163
`Attorney Docket: 39521-0007IP4
`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR § 42.6(e)(1), the undersigned certifies that on July 22,
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`2015, a complete and entire copy of this Petitioner Apple Inc.’s Unopposed Motion
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`for Pro Hac Vice Admission Under 37 C.F.R. § 42.10(c) and its supporting exhibit
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`were provided via email to the Patent Owner by serving the email correspondence
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`addresses of record as follows:
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`Jonathan D. Baker
`Bryan Atkinson
`Farney Daniels PC
`800 S. Austin, Suite 200
`Georgetown, TX 78626
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`Email: jbaker@farneydaniels.com
`Email: batkinson@farneydaniels.com
`Email: fdlistsupport@farneydaniels.com
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`/Edward G. Faeth/
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`Edward G. Faeth
`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`(202) 626-6420
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`5
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