UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
`
`ZHONGSHAN BROAD OCEAN MOTOR CO., LTD.,
`Petitioner,
`
`v.
`
`NIDEC MOTOR CORPORATION,
`Patent Owner.
`___________________________
`
`Case IPR2015-00762
`Patent 7,626,349
`___________________________
`
`ZHONGSHAN BROAD OCEAN MOTOR CO., LTD. ET AL.’S
`MOTION FOR PRO HAC VICE ADMISSION OF CHARLES S. BAKER
`
`NY 787110v.1
`
`
`___________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________________
`
`ZHONGSHAN BROAD OCEAN MOTOR CO., LTD.,
`Petitioner,
`
`v.
`
`NIDEC MOTOR CORPORATION,
`Patent Owner.
`___________________________
`
`Case IPR2015-00762
`Patent 7,626,349
`___________________________
`
`ZHONGSHAN BROAD OCEAN MOTOR CO., LTD. ET AL.’S
`MOTION FOR PRO HAC VICE ADMISSION OF CHARLES S. BAKER
`
`NY 787110v.1
`
`
`
`I.
`
`RELIEF REQUESTED
`
`Pursuant to the Board’s authorization for the parties to file motions for pro
`
`hac vice admission under 37 CFR §42.10(c) in the Notice of Filing Date Accorded
`
`to Petition and Time for Filing Patent Owner Preliminary Response dated
`
`March 10, 2015 (“the Notice”), Petitioner Zhongshan Broad Ocean Motor Co.,
`
`Ltd., Broad Ocean Motor LLC, and Broad Ocean Technologies, LLC requests that
`
`the Board admit Charles S. Baker pro hac vice in this proceeding. As required by
`
`the Notice, the following motion for pro hac vice admission is filed in accordance
`
`with “Order -- Authorizing Motion for Pro Hac Vice Admission” in Case
`
`No. IPR2013-00639 (“the Representative Order”).
`
`Pursuant to the Representative Order, this motion is being filed no sooner
`
`than 21 days after the service of the petition.
`
`II.
`
`STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE BOARD TO
`RECOGNIZE COUNSEL PRO HAC VICE DURING THE PROCEEDING
`
`In accordance with 37 CFR §42.10(c), the Board may recognize counsel pro
`
`hac vice during a proceeding upon showing of good cause, subject to the condition
`
`that lead counsel be a registered practitioner and to any other conditions as the
`
`Board may impose. Section 42.10(c) indicates that, “where lead counsel is a
`
`registered practitioner, a motion to appear pro hac vice may be granted upon a
`
`showing that counsel is an experienced litigating attorney and has an established
`
`NY 787110v.1
`
`1
`
`
`
`familiarity with the subject matter at issue in the proceeding.” The facts detailed
`
`herein establish good cause for the Board to recognize Charles S. Baker pro hac
`
`vice during this proceeding.
`
`1.
`
`Lead counsel, Steven F. Meyer, is a registered practitioner (Reg.
`
`No. 35,613).
`
`2.
`
`Backup counsel, Charles S. Baker, is an experienced litigator and has
`
`an established familiarity with the subject matter at issue in the proceeding.
`
`Exhibit 1011 is the Declaration of Charles S. Baker in Support of this Motion for
`
`Admission Pro Hac Vice of Charles S. Baker (“Baker Declaration”).
`
`In his
`
`declaration, Mr. Baker attests, inter alia, that: “I am a member in good standing of
`
`the Bar of the State of Texas and am admitted to practice before the United States
`
`Supreme Court, United States Courts of Appeals for the Fifth, Ninth and Federal
`
`Circuits, the United States District Courts for the Northern, Southern, Eastern and
`
`Western Districts of Texas, United States Tax Court and United States Court of
`
`Federal Claims. I am a member of the State Bar of Texas, as well as the American,
`
`Federal, Houston, Travis County and Fifth Federal Circuit Bar Associations,
`
`American Intellectual Property Law Association,
`
`International Trademark
`
`Association, International Trade Commission Trial Lawyers Association, Houston
`
`Intellectual Property Law Association and Defense Counsel of America.
`
`I have
`
`NY 787110v.1
`
`2
`
`
`
`been in private practice since November 1985 and litigating patent cases since
`
`September 1993.” Ex. 1011, Baker Declaration at ¶¶ 2-4.
`
`3.
`
`Mr. Baker also attests that: “I am familiar with the subject matter at
`
`issue in the proceeding. I am lead counsel in the following proceeding, which is a
`
`related matter and involves the same patent at issue in this proceeding: Nidec
`
`Motor Corporation v. Broad Ocean Motor LLC et al., Civil Action No. 4:13-CV-
`
`01895-JCH (E. D. Mo.) (filed September 25, 2013). Ex. 1011, Baker Declaration
`
`at ¶10. Additionally, Mr. Baker attests that “[a]s part of my role in the above
`
`related proceeding I have extensively reviewed and analyzed the patent at issue as
`
`well as the presently cited art.” Ex. 1011, Baker Declaration at ¶ 12.
`
`4.
`
`In his Declaration, Mr. Baker also attests to each of the listed items
`
`required by 37 CFR § 42.10(c). See Ex. 1011, Baker Declaration at ¶¶ 1-11.
`
`NY 787110v.1
`
`3
`
`
`
`III.
`
`CONCLUSION
`
`For the foregoing reasons, Petitioner Zhongshan Broad Ocean Motor Co.,
`
`Ltd., Broad Ocean Motor LLC, and Broad Ocean Technologies, LLC requests that
`
`the Board admit Charles S. Baker pro hac vice in this proceeding.
`
`Dated: March 16, 2015
`
`Respectfully submitted,
`
`/ Steven F. Meyer /
`Steven F. Meyer (Reg. No. 35,613)
`LOCKE LORD LLP
`Three World Financial Center
`New York, New York 10281-2101
`(212) 415-8535
`smeyer@lockelord.com
`
`Attorneys for Petitioner Zhongshan
`Broad Ocean Motor Co., Ltd.;
`Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`NY 787110v.1
`
`4
`
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. §42.6(e) and 37 C.F.R. §42.105(b), the undersigned
`hereby certifies that on March 16, 2015, a complete and entire copy of the
`foregoing Motion for Pro Hac Vice Admission of Charles S. Baker and
`attached Declaration were electronically served in their entirety on the Patent
`Owner of record (as agreed upon by counsel) at sbrown@hoveywilliams.com,
`mwalters@hoveywilliams.com, and litigation@hoveywilliams.com.
`
`Additionally, the undersigned certifies that on March 16, 2015, a complete
`and entire copy of the foregoing Motion for Pro Hac Vice Admission of
`Charles S. Baker and attached Declaration were electronically served on the
`Patent Owner’s below-listed counsel of record at jschwent@thompsoncoburn.com,
`djinkins@thompsoncoburn.com,
`and
`syoo@thompsoncoburn.com,
`in
`the
`co-pending litigation Nidec Motor Corporation v. Broad Ocean Motor LLC et al.,
`Civil Action No. 4:13-CV-01895-JCH (E.D. Mo.), as agreed upon by the parties.
`
`Dated: March 16, 2015
`
`/ Steven F. Meyer /
`Steven F. Meyer (Reg. No. 35,613)
`LOCKE LORD LLP
`Three World Financial Center
`New York, New York 10281-2101
`(212) 415-8535
`smeyer@lockelord.com
`
`Attorneys for Petitioner Zhongshan
`Broad Ocean Motor Co., Ltd.;
`Broad Ocean Motor LLC; and
`Broad Ocean Technologies, LLC
`
`NY 787110v.1
`
`
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