`
`_______________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_______________________________
`
`LUPIN LTD. and LUPIN PHARMACEUTICALS INC.
`Petitioners
`
`v.
`
`SENJU PHARMACEUTICAL CO., LTD., BAUSCH & LOMB, INC., and
`BAUSCH & LOMB PHARMA HOLDINGS CORP.
`Patent Owner
`
`____________________
`
`
`
`IPR2015-01097 (US Patent No. 8,751,131)
`IPR2015-01099 (US Patent No. 8,669,290)
`IPR1015-01100 (US Patent No. 8,927,606)
`IPR2015-01105 (US Patent No. 8,871,813)1
`____________________
`
`
`
`MOTION FOR PRO HAC VICE ADMISSION
`OF CHIEMI SUZUKI
`
`
`
`
`
`
`
`
`
`1 The word-for-word identical paper is filed in each proceeding identified in the
`heading.
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`
`
`
`
`
`
`
`
`
`Pursuant to 37 C.F.R. § 42.10(c), Lupin Ltd. and Lupin Pharmaceuticals Inc.
`
`(collectively, “Petitioners”), respectfully request the pro hac vice admission of
`
`Chiemi Suzuki as backup counsel for Petitioners in the current proceedings. Patent
`
`Owners have stated that they do not oppose this motion.
`
`In support of this unopposed motion, a declaration of Chiemi Suzuki is
`
`submitted as Exhibit 1075 explaining that she satisfies all the criteria for pro hac
`
`vice admission as set forth in Unified Patents, Inc. v. Parallel Iron, LLC, IPR2013-
`
`00639, Paper 7 (Oct. 15, 2013).
`
`I. Statement of Facts
`
`1.
`
`Patent Owner has informed Petitioners that their Patent Owner
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`Responses that will be forthcoming in these proceedings will include declarations
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`from a number of experts. Thus, Petitioners anticipate the need for additional
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`resources being assigned to these proceedings in the coming months. Accordingly,
`
`Petitioners respectfully request the pro hac vice admission of Ms. Suzuki, who is a
`
`very experienced patent litigator that has established a familiarity with the subject
`
`matter at issue in these proceedings.
`
`2. Ms. Suzuki is a member in good standing of the New York and
`
`California Bars. She has not had any application denied for admission to practice,
`
`nor has she been sanctioned, cited for contempt, suspended or disbarred from
`
`practice, before any court or administrative body.
`
`
`
`
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`
`
`
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`3. Ms. Suzuki is a litigation attorney with over 11 years of experience
`
`litigating patents in the pharmaceutical field.
`
`4. Ms. Suzuki is familiar with the subject matter at issue in these
`
`proceedings, including U.S. Pat. Nos. 8,751,131 (“the ‘131 patent”), 8,669,290
`
`(“the ‘290 patent”), 8,927,606 (“the ‘606 patent”) and 8,871,813 (“the ‘813
`
`patent”), the Petitions relating to these four patents filed by Petitioners, and the
`
`underlying technology as shown in her accompanying February 4, 2016
`
`Declaration (“Suzuki Declaration,” Ex. 1075).
`
`5.
`
`In her declaration, Ms. Suzuki also attests to each of the listed items
`
`required by the Order – Authorizing Motion for Pro Hac Vice Admission – 37
`
`C.F.R. § 42.10 in IPR2013-00639. Suzuki Declaration ¶¶ 1-11 (Ex. 1075).
`
`II. Conclusion
`
`For the foregoing reasons, Petitioners respectfully request that the Board
`
`admit Chiemi Suzuki pro hac vice in these proceedings.
`
`
`
`
`February 4, 2016
`
`Respectfully submitted,
`
`
`
` /Deborah Yellin/
`Deborah H. Yellin
`Reg. No. 45,904
`CROWELL & MORING LLP
`Intellectual Property Group
`P.O. Box 14300
`Washington, DC 20044-4300
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that the foregoing “MOTION FOR PRO
`
`HAC VICE ADMISSION OF CHIEMI SUZUKI” and accompanying Exhibit 1075
`
`were served electronically via email on February 4, 2016 to Patent Owner’s
`
`counsel of record upon the following:
`
`Bryan C. Diner
`Bryan.Diner@finnegan.com
`
`Justin J. Hasford
`Justin.Hasford@finnegan.com
`
`Joshua L. Goldberg
`Joshua.Goldberg@finnegan.com
`
`
`
`
`February 4, 2016
`
`
`
`
`Respectfully submitted,
`
`
`
`/Deborah Yellin/
`Deborah H. Yellin
`Reg. No. 45,904
`CROWELL & MORING LLP
`Intellectual Property Group
`P.O. Box 14300
`Washington, DC 20044-4300
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