Katherine D. Cappaert
`
`From:
`
`Sent:
`To:
`
`Cc:
`Subject:
`
`Vignone, Maria <Maria.Vignone@USPTO.GOV> on behalf of Trials
`<Trials@USPTO.GOV>
`Wednesday, April 29, 2015 4:30 PM
`Roberto Devoto; Underwood, Cathy; Michael L. Kiklis; dberl@wc.com;
`tfletcher@wc.com; jberniker@wc.com; csuarez@wc.com; IPR37136-0004IP1; CP Docket
`McKeown; CP Docket Kiklis; CP Docket Laurence; CP Docket Cappaert;
`CPDocketRicciuti; CP Docket Cappaert; Trials
`Arlenette Footes; Karl Renner; David Holt
`RE: Requested Conference Call Related To - IPR2014-00687; 00688; 00689
`
`Counsel:
`
`The parties are expected to work together to ensure timely filing of papers so that the Board can effectively deal with
`the issues arising in these proceedings. Counsel for ION is authorized to file a Motion for Pro Hac Vice for David Healey,
`which, to accommodate the deposition tomorrow, should be filed by 6pm EST this evening. The motion must indicate if
`it is unopposed. If it is opposed, an opposition to the same must be filed by 7 pm EST this evening.
`
`Thank you,
`
`Maria Vignone
`Paralegal Operations Manager
`Patent Trial and Appeal Board
`571-272-4645
`
`
`
`From: Roberto Devoto [mailto:devoto@fr.com]
`Sent: Wednesday, April 29, 2015 7:54 AM
`To: Underwood, Cathy; Michael L. Kiklis; dberl@wc.com; tfletcher@wc.com; jberniker@wc.com; csuarez@wc.com;
`IPR37136-0004IP1; CP Docket McKeown; CP Docket Kiklis; CP Docket Laurence; CP Docket Cappaert; CPDocketRicciuti;
`CP Docket Cappaert; Trials
`Cc: Arlenette Footes; Karl Renner; David Holt
`Subject: Requested Conference Call Related To - IPR2014-00687; 00688; 00689
`
`
`
`?Dear Ms. Underwood
`
`
`
`Pursuant to the e-mail sent last night, ION would like to file a Motion for Pro Hac Vice to allow our colleague,
`David Healey, to observe the deposition scheduled on 4/30/15. Pursuant to the Grant of Motion for Joinder
`(e.g., Paper 14 of IPR2015-00565), "ION ... is permitted to appear in [the joined proceeding] so that it ... may
`attend depositions..." As will be reflected in our motion, we wish to designate David to represent ION as an
`observer at the deposition because: (1) unlike Karl (lead counsel) and me (backup counsel), he is located in
`Houston, Texas and the deposition is in Houston, Texas; and (2) he has been involved in the counterpart
`litigation on behalf of ION over the same patents at issue in these proceedings, which makes him uniquely
`equipped to act on ION's behalf in these matters.
`
`1
`
`WesternGeco Ex. 2006, pg. 1
`IPR2015-00565
`ION v WesternGeco
`
`

`

`
`
`
`Unfortunately, we are unable to file our Motion via PRPS, which only allows the original petitioner's lead and
`backup counsel (i.e., PGS's lead and backup counsel) to submit filings. One known workaround for this
`problem is to have the original petitioner's counsel (i.e. PGS) add the lead and backup counsel of the joining
`petitioner (i.e., ION) as backup counsels to the joined proceedings on PRPS. However, PGS is not comfortable
`adding Karl Renner (ION lead counsel) and me (ION Backup counsel) as backup counsel to the proceedings. In
`view of this, we wish to have a call with the Board to resolve this problem so as to allow ION to submit the
`Motion for Pro Hac Vice today for expedited consideration by the Board and in advance of the 4/30/15
`deposition.
`
`
`
`The representatives of the Patent Owner are available between 10am and 5pm. ION's representatives are
`available between 11am and 5pm, and the representatives of PGS are available this morning and, with this e-
`mail, may provide further availability if needed.
`
`
`
`We look forward to hearing from you about the Board's availability for such a call.
`
`
`
`Kind Regards,
`
`-Rob
`
`ION Backup Counsel
`
`
`Roberto J. Devoto
`Principal
`~ Fish & Richardson P.C.
`1425 K Street, N.W., 11th Floor
`Washington, DC 20005
`devoto@fr.com<mailto:devoto@fr.com>
`M: 703.731.8596
`O: 202.626.6393
`
`
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`and privileged information. Any unauthorized use or disclosure is prohibited. If you are not the
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`message.
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`
`2
`
`WesternGeco Ex. 2006, pg. 2
`IPR2015-00565
`ION v WesternGeco
`
`