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UNITED STATES PATENT AND TRADEMARK OFFICE
`____________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________________________
`
`DISH NETWORK L.L.C.,
`
`Petitioner,
`
`v.
`
`DRAGON INTELLECTUAL PROPERTY, LLC,
`
`Patent Owner.
`____________________________
`
`Case IPR2015-00499
`Patent 5,930,444
`____________________________
`
`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION
`FOR COUNSEL TO WITHDRAW
`
`
`
`
`
`
`
`

`
`On November 3, 2015, Patent Owner Dragon filed a Motion for Counsel to
`
`Withdraw from the Proceeding and Permit Substitution of Counsel (“Motion”)
`
`requesting that Dragon’s 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.
`
`Contingent upon Dragon promptly (by Tuesday, November 10) providing a
`
`range of dates on which DISH Network L.L.C. (“DISH”) can depose Dragon’s
`
`expert – Adam Goldberg – DISH does not oppose the pending Motion.
`
`DISH expressly reserves and does not waive its right to pursue attorneys’
`
`fees and costs from either Mr. Angell or Mr. Freitas in the co-pending District
`
`Court action (Dragon Intellectual Property, LLC v. DISH Network L.L.C., No. 13-
`
`2066-RGA (D. Del.)), including any attorneys’ fees and costs related to this IPR.
`
`
`
`
`
`Respectfully submitted,
`
` /Eliot D. Williams/
`
`
`
`
`
`
`
`
`
`
`
`
`
`Dated: November 6, 2015
`
`Eliot D. Williams (Reg. No. 50,822)
`G. Hopkins Guy III (Reg. No. 35,866)
`1001 Page Mill Road, Bld. 1, Suite 200
`Palo Alto, California 94304-1007
`650.739.7510
`
`Attorneys for Petitioner
`DISH Network L.L.C.
`
`1
`
`
`
`
`
`
`
`

`
`CERTIFICATE OF SERVICE
`In accordance with 37 C.F.R. § 42.6(e), the undersigned certifies that on the
`6th day of November, 2015, a complete and entire copy of the foregoing
`PETITIONER’S RESPONSE TO PATENT OWNER’S MOTION FOR
`COUNSEL TO WITHDRAW, including exhibits and testimony relied upon,
`were served on the Patent Owner electronically at the email addresses below:
`
`Jason Angell
`Freitas Angell & Weinberg LLP
`350 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`jangell@fawlaw.com
`
`Robert E. Freitas
`Freitas Angell & Weinberg LLP
`350 Marine Parkway, Suite 200
`Redwood Shores, CA 94065
`rfreitas@fawlaw.com
`
`Kai Zhu (Reg. No. 64,586)
`60 Cody Ln
`Los Altos, CA 94022
`Telephone: (650) 999-0172
`Facsimile: (928) 569-1639
`kz@dragonipllc.com
`
`
`
`
`
`
`
`Dated: November 6, 2015
`
`
`
`
`
`
`
` /Eliot D. Williams/
`Eliot D. Williams (Reg. No. 50,822)
`G. Hopkins Guy III (Reg. No. 35,866)
`1001 Page Mill Road, Bld. 1, Suite 200
`Palo Alto, California 94304-1007
`650.739.7510
`
`Attorneys for Petitioner
`DISH Network L.L.C.
`
`2
`
`  

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