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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`MERCEDES-BENZ USA, LLC and
`MERCEDES-BENZ U.S. INTERNATIONAL, INC.,
`Petitioners,
`v.
`INNOVATIVE DISPLAY TECHNOLOGIES LLC,
`Patent Owner.
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`U.S. Patent No. 7,434,974
`IPR Case No.: IPR2015-00368
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`PETITIONERS’ MOTION FOR WITHDRAWAL OF COUNSEL
`AND TO PERMIT SUBSTITUTION OF COUNSEL
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`DMSLIBRARY01:24499800.2
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`I.
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`Statement of Precise Relief Requested
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`Pursuant to 37 C.F.R. § 42.10 and the direction provided by the Board in a
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`February 11, 2015 email from Ms. Maria Vignone, Petitioners Mercedes-Benz
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`USA, LLC and Mercedes-Benz U.S. International, Inc. (“Petitioners”) respectfully
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`request that the Patent Trial and Appeal Board (“the Board”) authorize withdrawal
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`of Petitioners’ current counsel, Scott T. Weingaertner and Natasha H. Moffitt, and
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`permit substitution of new counsel. Counsel for Patent Owner, Innovative
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`Display Technologies LLC, has no objections to the withdrawal of Mr.
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`Weingaertner and Ms. Moffitt, and the substitution of new counsel.
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`II.
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`Statement of Facts Showing Good Cause for the Board to Authorize
`Withdrawal of Counsel and Substitution of New Counsel
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`On December 3, 2014, Petitioners appointed Scott T. Weingaertner and
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`Natasha H. Moffitt as their attorneys in the above-captioned inter partes review.
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`Petitioners request that current designated counsel, Mr. Weingaertner and Ms.
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`Moffitt, be allowed to withdraw from the present proceeding, and new counsel,
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`Mr. Scott W. Doyle, a registered practitioner, be designated as lead counsel to
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`represent Petitioners in this proceeding. Petitioners intend to appoint new counsel
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`as follows:
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`Lead Counsel: Mr. Scott W. Doyle (Reg. No. 39,176)
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`Shearman & Sterling LLP
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`801 Pennsylvania Avenue, NW
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`Washington, D.C. 20004
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`DMSLIBRARY01:24499800.2
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`Tel.: (202) 508-8170
`Email: Scott.Doyle@Shearman.com
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`Mr. Doyle will have the power to prosecute the proceedings, transact all business
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`with the Patent and Trademark Office concerned therewith, and appoint backup
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`counsel.
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`No extensions of time will be needed upon the granting of this motion
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`because the inter partes review has not yet been instituted. Thus, the substitution
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`of counsel will not cause any delay in the proceeding or any prejudice to the
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`Patent Owner.
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`Accordingly, Petitioners respectfully request that the Board grant their
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`motion to authorize withdrawal of counsel and substitute new counsel. Upon the
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`granting of this motion, Petitioners’ substitute counsel will promptly file a new
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`Power of Attorney and an Updated Mandatory Notice in accordance with the
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`Board’s instructions in the February 11, 2015 email from Ms. Vignone.
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`Respectfully submitted, this 23rd day of February, 2015.
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`/Scott T. Weingaertner/
`Scott T. Weingaertner (Reg. No. 37,756)
`KING & SPALDING LLP
`1185 Avenue of the Americas
`New York, NY 10036-2601
`Tel.: (212) 556-2227
`Fax: (212) 556-2222
`Email: sweingaertner@kslaw.com
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`Natasha H. Moffitt (Reg. No. 53,340)
`KING & SPALDING LLP
`1180 Peachtree Street, NE
`Atlanta, GA 30309
`Tel.: (404) 572-2783
`Fax: (404) 572-5134
`Email: nmoffitt@kslaw.com
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`Counsel for Petitioners
`MERCEDES-BENZ USA, LLC and
`MERCEDES-BENZ U.S.
`INTERNATIONAL, INC.
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`CERTIFICATE OF SERVICE
`I hereby certify that the foregoing PETITIONERS’ MOTION FOR
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`WITHDRAWAL OF COUNSEL AND TO PERMIT SUBSTITUTION OF
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`COUNSEL was served by electronic mail on counsel for the Patent Owner as
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`follows:
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`Justin B. Kimble (jkimble@bcpc-law.com)
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
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`This 23rd day of February, 2015.
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`/Scott T. Weingaertner/
`Scott T. Weingaertner (Reg. No. 37,756)
`KING & SPALDING LLP
`1185 Avenue of the Americas
`New York, NY 10036-2601
`Tel.: (212) 556-2227
`Fax: (212) 556-2222
`Email: sweingaertner@kslaw.com
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`DMSLIBRARY01:24499800.2
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