`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`MICROSOFT CORPORATION,
`Petitioner
`
`V.
`
`BRADIUM TECHNOLOGIES LLC,
`Patent Owner
`
`Case IPR2015-01435
`
`Patent 8,924,506 B2
`
`MOTION FOR PRO HAC VICE ADMISSION
`
`OF ROBIN M. PLACHY
`
`
`
`Pursuant to 37 C.F.R. § 42. l0(c), Patent Owner respectfully requests the pro
`
`hac vice admission of Robin M. Plachy as backup counsel for Patent Owner in the
`
`current proceedings. A declaration made by Ms. Plachy in support of this motion
`
`is attached hereto as Exhibit A.
`
`1.
`
`Statement of Facts
`
`1.
`
`Ms. Plachy is a litigation attorney experienced in patent cases,
`
`and is admitted to practice law in New York and Massachusetts State, as
`
`well as the U.S. District Court for the Southern District of New York.
`
`2.
`
`Ms. Plachy 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.
`
`3.
`
`Ms. Plachy has an established familiarity with the subject
`
`matter at issue in this proceeding, having represented Patent Owner in a
`
`Delaware District court proceeding against Petitioner involving the same
`
`technology (Bradium Techs. LLC V. Microsoft Corp. , 1:l5—cV-0003 l—RGA).
`
`4.
`
`Ms. Plachy 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 the C.F.R.
`
`
`
`2.
`
`Conclusions
`
`For the reasons stated above, Patent Owner respectfully submits that there is
`
`good cause for the Board to recognize Robin M. Plachy pro hac vice during the
`
`proceeding.
`
`Dated: August 4, 2015
`
`(S1 (Zbris J. Coulson
`KENYON & KENYON LLP
`
`One Broadway
`New York, NY 10004-1007
`Te1.: (212)425-7200
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing “MOTION FOR PRO
`
`HAC VICE ADMISSION OF ROBIN M. PLACHY” was served Via electronic
`
`mail on August 4, 2015, on the Petitioner at the correspondence address of the
`
`Petitioner as follows:
`
`Bing Ai
`Matthew Bernstein
`
`Vinay Sathe
`Patrick McKeeVer
`
`PerkinsSerViceBradiurnIPR@perkinscoie.com
`
`/s/ Chris J. Coulson
`
`KENYON & KENYON LLP
`
`One Broadway
`New York, NY 10004-1007
`Tel.: (212) 425-7200
`
`
`
`EXHIBIT A
`
`
`
`I, ROBIN M. PLACHY, declare as follows:
`
`1.
`
`I am an associate at the law firm of Kenyon & Kenyon LLP, with offices located at
`
`One Broadway, New York, NY 10004, which has been retained by Patent Owner
`
`Bradium Technologies LLC in this inter partes review.
`
`2.
`
`I make this affidavit in support of the Patent Owner’s application for my
`
`admission pro hac vice.
`
`3.
`
`I am a member in good standing of the Bar in New York and Massachusetts
`
`State. I am also duly admitted and authorized to practice law before the U.S.
`
`District Court for the Southern District of New York.
`
`4. I have not had any application denied for admission to practice, nor have I been
`
`sanctioned, cited for contempt, suspended or disbarred from practice, before any
`
`court or administrative body.
`
`5. If admitted pro hac vice in this matter, I will serve as counsel with Michelle
`
`Carniaux, also of the law firm Kenyon & Kenyon. Ms. Carniaux is lead counsel
`
`on this case and is registered to practice in this Court.
`
`6.
`
`I have 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 the C.F.R.
`
`7.
`
`I understand that, upon admission pro hac vice, I will be subj ect to the USPTO
`
`Rules of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and to
`
`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
`
`
`
`8.
`
`I hereby agree to notify the Court immediately of any matter affecting my
`
`standing at the bar of any other Court.
`
`9.
`
`I have not applied to appear pro hac vice before the Office in the last three years.
`
`I have appeared pro hac vice before several district courts, including the
`
`following litigations: Taino/lpp, Inc. v. Sony El€CS.,
`
`Inc. 3—l4—cV—0l2l5 (D.P.R.
`
`Mar. 17, 2014); Am. ’S Collectibles Network, Inc. v. Jewelry Channel, Inc., 3-13-
`
`cV—00334 (E.D. Tenn. June 13, 2013); MONKEYmedia, Inc. v. Buena Vista
`
`Home Enz‘. ,
`
`l—l0—cV—0O533 (W.D. Tex. July 19, 2010).
`
`10. I have an established familiarity with the subject matter at issue in this
`
`proceeding, having represented Patent Owner in a Delaware District court
`
`proceeding against Petitioner involving the same technology (Bradium Techs.
`
`LLC v. Illicrosofi Corp., 1:15-CV-0003 l—RGA).
`
`11. I hereby respectfully request that the Court grant Patent Owner Bradium
`
`Technologies LLC’s application to permit me to appear and participate pro lzac
`
`vice in this case.
`
`
`
`12. I understand that willful false statements and the like are punishable by fine or
`
`imprisonment, or both, under 18 U.S.C. 1001, and may jeopardize the Validity of
`
`the application or any patent issuing thereon.
`
`I declare under penalty of perjury
`
`that the foregoing is true and correct.
`
`5:’
`
`J
`
`Executed on: August 3, 2015
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