By: Vivek Ganti (vg@hkw-law.com)
`Reg. No. 71368
`Gregory Ourada (go@hkw-law.com)
`Reg. No. 55516
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`AMERICAN MEGATRENDS, INC.,
`MICRO-STAR INTERNATIONAL CO., LTD,
`MSI COMPUTER CORP.,
`GIGA-BYTE TECHNOLOGY CO., LTD., AND
`G.B.T., INC.
`Petitioners
`
`v.
`
`KINGLITE HOLDINGS, LLC
`
`Patent Owner
`
`_________________
`
`Case IPR2015-01191
`U.S. Patent No. 6,892,304
`_________________
`
`PETITIONERS’ MOTION FOR PRO HAC VICE
`ADMISSION OF STEVEN G. HILL
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`Reg. No. 71368
`Gregory Ourada (go@hkw-law.com)
`Reg. No. 55516
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`AMERICAN MEGATRENDS, INC.,
`MICRO-STAR INTERNATIONAL CO., LTD,
`MSI COMPUTER CORP.,
`GIGA-BYTE TECHNOLOGY CO., LTD., AND
`G.B.T., INC.
`Petitioners
`
`v.
`
`KINGLITE HOLDINGS, LLC
`
`Patent Owner
`
`_________________
`
`Case IPR2015-01191
`U.S. Patent No. 6,892,304
`_________________
`
`PETITIONERS’ MOTION FOR PRO HAC VICE
`ADMISSION OF STEVEN G. HILL
`
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`
`Petition for Inter Partes Review of U.S. Pat. No. 6,892,304
`
`
`I. Relief Requested
`
`Pursuant to 37 C.F.R. § 42.10, Petitioners request that the Board admits
`
`Steven G. Hill pro hac vice in this proceeding.
`
`II. Statement of Facts Showing Good Cause for the Board to Recognize
`Counsel pro hac vice during the Proceeding
`
`
`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel
`
`pro hac vice during a proceeding, subject to the conditions set forth therein, and
`
`any others that the Board may impose. Petitioners set forth these facts in support
`
`of this motion:
`
`1. Lead counsel for Petitioners in this proceeding, Vivek Ganti, is a
`
`registered practitioner (Registration No. 71,368).
`
`2. Steven G. Hill is an experienced litigator and has established familiarity
`
`with the subject matter of this proceeding. Accompanying this motion as
`
`Ex. 1028, the Declaration of Steven G. Hill in Support of this Motion for
`
`Admission Pro Hac Vice (“Hill Dec.”). (Ex. 1028, ¶ 1)
`
`3. Mr. Hill is a member in good standing of the Bar of Georgia. (Id., ¶ 2).
`
`4. Mr. Hill has had no suspensions or disbarments from practice before any
`
`court or administrative body. (Id., ¶ 3). In addition, no application for
`
`admission to practice before any court or administrative body ever denied
`
`and no sanctions or contempt citations have been imposed on Mr. Hill by
`
`any court or administrative body. (Id.).
`1
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`Petition for Inter Partes Review of U.S. Pat. No. 6,892,304
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`5. Mr. Hill has read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of
`
`37 C.F.R. (Id., ¶ 4).
`
`6. Mr. Hill agrees to be subject to the United States Patent and Trademark
`
`Office Rules of Professional Conduct as set forth in 37 C.F.R. §§ 11.101
`
`et seq., and disciplinary jurisdiction under 37 C.F.R. § 11.19(a). (Id., ¶
`
`5).
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`7. In the past three (3) years, Mr. Hill has appeared pro hac vice in
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`IPR2013-00302 and IPR2013-00309 before the United States Patent and
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`Trademark Office. (Id., ¶ 6).
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`8. Mr. Hill has familiarity with the subject matter at issue in the proceeding.
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`(Id., ¶ 7). Specifically, Mr. Hill is lead counsel in the district court case
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`relating to the patent-at-issue. (Id., ¶ 9). He has reviewed the patent-at-
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`issue as well as the prior art in the instant proceeding. (Id., ¶8).
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`III. Conclusion
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`For the foregoing reasons, Petitioners respectfully request that the Board
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`admit Mr. Hill pro hac vice in this proceeding.
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`HILL, KERTSCHER & WHARTON, LLP
`
`/Vivek Ganti/
`
`
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`Petition for Inter Partes Review of U.S. Pat. No. 6,892,304
`
`
`Date: November 24, 2015
`
` Vivek Ganti (Registration No. 71,368)
`Lead Counsel for Petitioners
`3350 Riverwood Pkwy, Suite 800
`Atlanta, GA 30339
`(770) 953-0995
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`Petition for Inter Partes Review of U.S. Pat. No. 6,892,304
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`PETITIONERS’ CURRENT EXHIBIT LIST
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`Exhibit No.
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`Document Description
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`Ex. 1001
`Ex. 1002
`Ex. 1003
`
`Ex. 1004
`Ex. 1005
`Ex. 1006
`
`Ex. 1007
`Ex. 1008
`Ex. 1009
`Ex. 1010
`Ex. 1011
`Ex. 1012
`Ex. 1013
`Ex. 1014
`Ex. 1015
`Ex. 1016
`Ex. 1017
`Ex. 1018
`Ex. 1019
`
`Ex. 1020
`Ex. 1021
`Ex. 1022
`Ex. 1023
`Ex. 1024
`Ex. 1025
`Ex. 1026
`Ex. 1027
`Ex. 1028
`
`U.S. Patent No. 6,892,304 to Galasso et al. (“304 Patent”)
`The file history of the 304 Patent
`The file history of U.S. Patent Appl. No. 08/947,990
`(“The CIP”)
`U.S. Patent No. 5,844,986 to Davis (“Davis”)
`PKCS #1: RSA Cryptography Standard
`Automated Recovery in a Secure Bootstrap Process
`(“Aegis”)
`U.S. Patent No. 6,539,480 to Drews (“Drews”)
`Bootup Integrity Service Specification (“BIS”)
`DHCP Protocol
`U.S. Patent No. 4,218,582 to Hellman et al. (“Hellman”)
`Drews Deposition Transcript (“Drews Depo. Trans”)
`Galasso Deposition Transcript (“Galasso Depo. Trans.”)
`AMIBIOS 98 Technical Reference (1998)
`U.S. Patent No. 4,405,829 to Rivest et al (“RSA Patent”)
`U.S. Patent No. 5,557,678 to Ganesan (“Ganesan”)
`U.S. Patent No. 6,041,357 to Kunzelman (“Kunzelman”)
`U.S. Patent No. 4,578,530 to Zeidler (“Zeidler”)
`CCITT Recommendation x.509 (1988)
`Federal Information Processing Standards Publication
`191 (“FIPS PUB 191”)
`U.S. Patent No. 5,732,268 to Bizzari (“Bizzari”)
`U.S. Patent No. 6,574,588 to Shapiro (“Shapiro”)
`U.S. Patent No. 5,586,301 to Fisherman (“Fisherman”)
`U.S. Patent No. 5,652,875 to Taylor (“Taylor”)
`U.S. Patent No. 6,081,890 to Datta (“Datta”)
`Schnier, B., Applied Cryptography (2d ed. 1996)
`Declaration of James Bottomley
`Declaration of Vivek Ganti
`Declaration of Steven G. Hill
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`Petition for Inter Partes Review of U.S. Pat. No. 6,892,304
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`CERTIFICATION OF SERVICE
`
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`The undersigned hereby certifies that the foregoing paper and supporting
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`Exhibit were served via electronic mail on November 24, 2015, as agreed to by the
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`parties pursuant to 37 C.F.R. § 42.105, in its entirety on the following:
`
`Respectfully submitted,
`
`HILL, KERTSCHER & WHARTON,
`LLP
`
`
`/Vivek Ganti/
`
`
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`Vivek Ganti (Reg. No. 71,368)
`Lead Counsel for Petitioners
`
`3350 Riverwood Pkwy, Suite 800
`Atlanta, GA 30339
`(770) 953-0995
`
`
`Christopher Frerking
`chris@ntknet.com
`174 Rumford Street
`Concord, New Hampshire 03301
`Telephone: (603) 706-3127
`
`George C. Summerfield
`summerfield@stadheimgrear.com
`STADHEIM & GREAR, LTD.
`400 N. Michigan Ave.,
`Suite 2200
`Chicago, Illinois 60611
`Telephone: (312) 755-4400
`
`
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`Date: November 24, 2015
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`
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`5
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