Filed on behalf of Delaware Display Group LLC
`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`Tel: 214.785.6670
`Fax: 214.786.6680
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LG DISPLAY CO., LTD.,
`Petitioner,
`
`v.
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`DELAWARE DISPLAY GROUP LLC,
`Patent Owner.
`
`
`
`Case IPR2015-00506
`U.S. Patent No. 7,434,973
`
`
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`PRO HAC VICE MOTION TO ADMIT ATTORNEY T. WILLIAM
`KENNEDY PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`
`
`By:
`Justin B. Kimble (JKimble-IPR@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`Tel: 214.785.6670
`Fax: 214.786.6680
`
`
`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`LG DISPLAY CO., LTD.,
`Petitioner,
`
`v.
`
`DELAWARE DISPLAY GROUP LLC,
`Patent Owner.
`
`
`
`Case IPR2015-00506
`U.S. Patent No. 7,434,973
`
`
`
`PRO HAC VICE MOTION TO ADMIT ATTORNEY T. WILLIAM
`KENNEDY PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`
`
`
`Case IPR2015-00506
`Patent 7,434,973
`
`
`
`Patent Owner Delaware Display Group LLC (“DDG”) hereby files this
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`motion pursuant to 37 C.F.R. § 42.10(c) for T. William Kennedy to appear pro hac
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`vice on its behalf before the Patent Trial and Appeal Board in IPR2015-00506. This
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`motion follows the guidelines set forth in IPR2013-00639, Paper 7, entered October
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`15, 2013.
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`I.
`
`Statement of Facts.
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`DDG has already designated a registered practitioner, Justin B. Kimble (reg.
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`no. 58,591) as lead counsel, and DDG intends to designate T. William Kennedy as
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`one of its back-up counsel in the event this motion is granted. The following
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`statement of facts shows that there is good cause for the Board to recognize T.
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`William Kennedy pro hac vice during this proceeding.
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`Mr. Kennedy is a patent litigator with over eight years’ experience, including
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`significant experience in the area of patent validity. In the many patent litigations in
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`which he has been counsel, he was worked extensively on issues relating to 35
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`U.S.C. §§ 102, 103, and 112 challenges to patent validity including things such as
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`working closely with experts on validity and invalidity reports, preparing invalidity
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`arguments for trial, developing invalidity and validity arguments, and reviewing and
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`analyzing numerous prosecution histories and prior art references. Mr. Kennedy has
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`also spent significant time learning the procedure of inter partes review.
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`Case IPR2015-00506
`Patent 7,434,973
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`Mr. Kennedy currently represents the Patent Owner in its assertion of the
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`patent at issue in this proceeding and its related patents in numerous cases resolved
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`in the Eastern District of Texas and pending in the District of Delaware. See, e.g.,
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`Delaware Display Group LLC et al. v. LG Electronics, Inc. et al., No. 1:13-cv-02109
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`(D. Del., filed Dec. 31, 2013); see also Delaware Display Group LLC et al. v. Vizio
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`Inc., et al., No. 1:13-cv-02112 (D. Del., filed Dec. 31, 2013). As counsel in those
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`actions, Mr. Kennedy has become very familiar the subject matter at issue in this
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`proceeding, i.e., light emitting panel assemblies. Moreover, during the course of
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`those lawsuits, Mr. Kennedy has analyzed the prior art involved in this petition as it
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`relates to the patent-at-issue as well as its related patents, all of which concern light
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`emitting panel assemblies. Furthermore, in those lawsuits Mr. Kennedy has
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`developed infringement allegations that assert the patent-at-issue in this petition
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`against various light emitting panel assemblies, including those found in smart
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`phones, tablets, laptop computers, and televisions to name a few. In his role as
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`counsel in those litigations, Mr. Kennedy has spent significant time learning the
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`technology involved in light emitting panel assemblies such as those found in the
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`patent-at-issue in this proceeding.
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`As of this date, there are currently 11 total pending IPRs covering the patent-
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`at-issue and its related patents. Mr. Kennedy has familiarized himself which each of
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`those pending petitions. Given the number of pending IPRs related to this patent
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`Case IPR2015-00506
`Patent 7,434,973
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`family and Mr. Kennedy’s already extensive knowledge of the patents, prior art, and
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`IPRs, Patent Owner asks the PTAB to grant this motion to afford Patent Owner the
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`benefit of having an additional attorney authorized on this matter.
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`II. Mr. Kennedy has Submitted Herewith a Declaration1 Attesting the
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`Following Facts.
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`1. Mr. Kennedy is a member in good standing of the Texas State Bar.
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`2. Mr. Kennedy has never been subject to any suspensions or disbarments
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`from practice before any court or administrative body.
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`3.
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`None of Mr. Kennedy’s applications for admission to practice before
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`any court or administrative body has ever been denied.
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`4. Mr. Kennedy has never been sanctioned nor had contempt citations
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`imposed by any court or administrative body.
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`5. Mr. Kennedy has read and will comply with the Office Patent Trial
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`Practice Guide and the Board’s Rules of Practice for Trials set forth in
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`part 42 of 37 C.F.R.
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`6. Mr. Kennedy will be subject to the USPTO Rules of Professional
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`Conduct set forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a).
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`1 See Declaration of T. William Kennedy, attached hereto as Exhibit 2006.
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`Case IPR2015-00506
`Patent 7,434,973
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`7.
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`During the past three years, Mr. Kennedy has applied to appear pro hac
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`vice before the PTAB in five other proceedings, all pending. All five of
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`the pro hac vice motions involve the same or related parties as this
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`proceeding and also involve the same or similar subject matter:
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`i. IPR2014-01096 (pending);
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`ii. IPR2014-01097 (pending);
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`iii. IPR2014-01362 (pending);
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`iv. IPR2015-00487 (pending); and
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`v. IPR2015-01717 (pending).
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`Mr. Kennedy has not applied to appear pro hac vice in any other
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`proceeding before the PTAB.
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`8. Mr. Kennedy has familiarity with the subject matter at issue in the
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`proceeding as set forth in Section I above.
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`
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`Dated: September 9, 2015 Respectfully submitted,
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`
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`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
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`Case IPR2015-00506
`Patent 7,434,973
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`CERTIFICATE OF SERVICE
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`
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`The undersigned hereby certifies that this document has been served via
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`electronic mail on September 9, 2015, to Petitioner at the email addresses
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`rpluta@mayerbrown.com, bpaul@mayerbrown.com, astreff@mayerbrown.com,
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`alam@mayerbrown.com,
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`jbeaber@mayerbrown.com,
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`and
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`DDGIPR@mayerbrown.com, pursuant to Petitioner’s consent in its revised
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`mandatory notice.
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`_____________________________
`
`Justin B. Kimble
`Attorney for Patent Owner
`Registration No. 58,591
`Bragalone Conroy P.C.
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`
`
`
`6
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