`______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
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`MICROSOFT CORPORATION,
`Petitioner
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`v.
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`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`______________
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`Case IPR2015-01432
`Patent 7,139,794 B2
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`MOTION FOR PRO HAC VICE ADMISSION
`OF MARK A. HANNEMANN
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`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner respectfully requests the pro
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`hac vice admission of Mark A. Hannemann as backup counsel for Patent Owner in
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`the current proceedings. A declaration made by Mr. Hannemann in support of this
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`motion is attached hereto as Exhibit A.
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`1.
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`Statement of Facts
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`1. Mr. Hannemann is a litigation attorney experienced in patent cases,
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`and is admitted to practice law in New York State, as well as the following Federal
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`Courts:
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`United States District Court for the Southern District of New York;
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`United States Court of Appeals for the Federal Circuit.
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`2. Mr. Hannemann has not had any application denied for admission to
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`practice, nor has he been sanctioned, cited for contempt, suspended or disbarred
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`from practice, before any court or administrative body.
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`3. Mr. Hannemann has an established familiarity with the subject matter
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`at issue in this proceeding, having represented Patent Owner in a Delaware District
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`court proceeding against Petitioner involving the same technology (Bradium
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`Techs. LLC v. Microsoft Corp., 1:15-cv-00031-RGA).
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`4. Mr. Hannemann 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 part 42 of
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`the C.F.R.
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`2.
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`Conclusions
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`For the reasons stated above, Patent Owner respectfully submits that there is
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`good cause for the Board to recognize Mark A. Hannemann pro hac vice during
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`the proceeding.
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`Dated: August 4, 2015
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`/s/ Chris J. Coulson
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
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`-3-
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that the foregoing “MOTION FOR PRO
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`HAC VICE ADMISSION OF MARK A. HANNEMANN” was served via
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`electronic mail on August 4, 2015, on the Petitioner at the correspondence address
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`of the Petitioner as follows:
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`Bing Ai
`Matthew Bernstein
`Vinay Sathe
`Patrick McKeever
`PerkinsServiceBradiumIPR@perkinscoie.com
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`
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`
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`/s/ Chris J. Coulson
`KENYON & KENYON LLP
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
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`-4-
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`EXHIBIT A
`EXHIBIT A
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`I, MARK A. HANNEMANN, declare as follows:
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`1. I am a partner at the law firm of Kenyon & Kenyon LLP, with offices located at One
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`Broadway, New York, NY 10004, which has been retained by Patent Owner Bradium
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`Technologies LLC in this inter partes review.
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`2. I make this affidavit in support of the Patent Owner’s application for my
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`admission pro hac vice.
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`3. I am a member in good standing of the Bar of the State of New York. I am also
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`duly admitted and authorized to practice law before the United States District
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`Court for the Southern District of New York and the United States Court of
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`Appeals for the Federal Circuit.
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`4. I have not had any application denied for admission to practice, nor have I been
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`sanctioned, cited for contempt, suspended or disbarred from practice, before any
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`court or administrative body.
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`5. If admitted pro hac vice in this matter, I will serve as counsel with Michelle
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`Carniaux, also of the law firm Kenyon & Kenyon. Ms. Carniaux is lead counsel
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`on this case and is registered to practice in this Court.
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`6. I understand that, upon admission pro hac vice, I will be subject to the USPTO
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`Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and to
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`7. I have read and will comply with the Office Patent Trial Practice Guide and the
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`Board's Rules of Practice for Trials set forth in part 42 of the C.F.R.
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`8. I hereby agree to notify the Court immediately of any matter affecting my
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`standing at the bar of any other Court.
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`9. I have not applied to appear pro hac vice in any matters before the Office in the
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`last three years. I have appeared pro hac vice before other courts including the
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`following litigations: Kangaroo Media, Inc. v. Yinzcam, Inc., Civil Action No.
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`12-0382, 2014 WL 3378692 (W.D. Pa. July 9, 2014); Advanced Ground Info.
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`Sys., Inc. v. Life360, Inc., Case No. 9:14-cv-80651, 2015 WL 4522718 (S.D. Fla
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`May 16, 2014); Robert Bosch LLC v. Alberee Prods., Civil Action No. 12-574-
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`LPS, 2014 U.S. Dist. LEXIS 137062 (D. Del. Sept. 29, 2014).
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`10. I have an established familiarity with the subject matter at issue in this
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`proceeding, having represented Patent Owner in a Delaware District court
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`proceeding against Petitioner involving the same technology (Bradium Techs.
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`LLC v. Microsoft Corp., 1:15-cv-00031-RGA).
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`11. I hereby respectfully request that the Court grant Patent Owner Bradium
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`Technologies LLC’s application to permit me to appear and participate pro hac
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`vice in this case.
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`12. I understand that willful false statements and the like are punishable by fine or
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`imprisonment, or both, under 18 U.S.C. 1001, and may jeopardize the validity of
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`the application or any patent issuing thereon. I declare under penalty of perjury
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`that the foregoing is true and correct.
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`Executed on: August 3, 2015
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`/s/ Mark A. Hannemann
`MARK A. HANNEMANN
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