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Case IPR2015-01501
`Patent No. 7,777,753 
`
` 
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`HTC AMERICA INC., HTC CORP., LG ELECTRONICS, INC.,
`LG ELECTRONICS U.S.A., INC.,
`LG ELECTRONICS MOBILECOMM U.S.A., INC.,
`SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA, INC.,
`Petitioner,
`
`v.
`
`PARTHENON UNIFIED MEMORY ARCHITECTURE LLC
`Patent Owner.
`____________
`
`Case IPR2015-01501
`Patent 7,777,753
`____________
`
`Mailed: July 8, 2015
`
`Before KAREN HILASKI, Trial Paralegal.
`
`
`PARTHENON UNIFIED MEMORY ARCHITECTURE LLC’s
`UNOPPOSED MOTION FOR PRO HAC VICE 37 C.F.R. 42.10
`
`The Patent Owner respectfully requests that the Board recognize Mr. Alavi
`
`
`
`Alavi as counsel pro hac vice during this proceeding.
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`
`
`

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`1. Time for Filing
`
`This Motion for Pro Hac Vice Admission is being filed no sooner than
`
`Case IPR2015-01501
`Patent No. 7,777,753 
`
`twenty one (21) days after service of the petition.
`
`2. Statement of Facts
`
`The following statement of facts shows that there is good cause for the
`
`Board to recognize Mr. Alavi as counsel for Patent Owner pro hac vice.
`
`Mr. Alavi is an experienced litigation attorney, and has been involved in a
`
`significant number of District Court litigations involving patent infringement,
`
`including jury trails and Markman hearings. Mr. Alavi’s biography is attached
`
`hereto as Exhibit A.
`
`U.S. Patent No. 7,777,753 (“the ‘753 Patent”) is currently asserted against
`
`Petitioners HTC Corporation, HTC America, Inc., LG Electronics, Inc., Samsung
`
`Electronics Co., Ltd., and Samsung Electronics America, Inc. in co-pending
`
`litigations in the U.S. District Court for the Eastern District of Texas: Parthenon
`
`Unified Memory Architecture LLC v. Huawei Techs. Co., Ltd. et al., No. 2:14-cv-
`
`00687-JRG-RSP (E.D. Tex.) filed June 12, 2014; Parthenon Unified Memory
`
`Architecture LLC v. Motorola Mobility, Inc., No. 2:14-cv-00689-JRG-RSP (E.D.
`
`Tex.) filed June 12, 2014; Parthenon Unified Memory Architecture LLC v. HTC
`
`Corp. et al., No. 2:14-cv-00690-RSP (E.D. Tex.) filed June 12, 2014; Parthenon
`
`Unified Memory Architecture LLC v. LG Elecs., Inc. et al., No. 2:14-cv-00691-
`
`2
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`

`
`Case IPR2015-01501
`Patent No. 7,777,753 
`JRG-RSP (E.D. Tex.) filed June 12, 2014; Parthenon Unified Memory
`
`Architecture LLC v. Samsung Elecs. Co., Ltd. et al., No. 2:14-cv-00902-JRG-RSP
`
`(E.D. Tex.) filed September 22, 2014; Parthenon Unified Memory Architecture
`
`LLC v. Qualcomm Inc. et al., No. 2:14-cv-00930-JRG-RSP (E.D. Tex.) filed
`
`October 1, 2014; Parthenon Unified Memory Architecture LLC v. ZTE Corp. et al.,
`
`No. 2:15-cv-00225-JRG-RSP (E.D. Tex.) filed February 17, 2015; Parthenon
`
`Unified Memory Architecture LLC v. Apple, Inc., No. 2:15-cv-00621-JRG-RSP
`
`(E.D. Tex) filed May 1, 2015; and Parthenon Unified Memory Architecture LLC v.
`
`LG Electronics Mobilcomm USA, Inc., No. 2:15-cv-1950 (E.D. Tex) filed
`
`November 30, 2015. Mr. Alavi is lead counsel for Parthenon Unified Memory
`
`Architecture, LLC in the co-pending litigation and, as such, has an established
`
`familiarity with the subject matter at issue in this proceeding. In the co-pending
`
`litigation Mr. Alavi argued the Markman hearings, reviewed prior art references
`
`and claim charts for invalidity contentions, and was heavily involved in forming
`
`claim construction positions and drafting claim construction briefs, all of which are
`
`relied upon in the petition requesting inter parties review of U.S. Patent No.
`
`7,777,753. Patent Owner has expended significant financial resources in the co-
`
`pending litigations with Mr. Alavi as counsel, and Patent Owner wishes to
`
`continue using Mr. Alavi as counsel in this proceeding.
`
`3
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`  
`
`

`
`Case IPR2015-01501
`Patent No. 7,777,753 
`Further, counsel for Petitioners does not oppose Mr. Alavi appearing pro hac
`
`vice this proceeding.
`
`Therefore, Patent Owner respectfully submits that there is good cause for the
`
`Board to recognize Mr. Alavi as counsel pro hac vice during this proceeding.
`
`3. Affidavit or Declaration of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is accompanied by Affidavit of
`
`Mr. Amir Alavi.
`
` Dated: March 4, 2016
`
`
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`Respectfully Submitted,
`By: /s/ Masood Anjom
`
`Masood Anjom
`
`Reg. No. 62,167
`Attorney for Patent Owner
`Parthenon Unified Memory
`Architecture, LLC
`
`AHMAD, ZAVITSANOS, ANAIPAKOS,
`ALAVI &MENSING, P.C.
`1221 McKinney Street, Suite 2500
`Houston, TX 77010
`Telephone: 713-655-1101
`
`4
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`

`
`Case IPR2015-01501
`Patent No. 7,777,753 
`
`CERTIFICATE OF SERVICE
`I hereby certify that Parthenon Unified Memory Architecture LLC’s Motion
`
`for Pro Hac Vice Admission Under 37 C.F.R. 42.10 were served on March 4,
`2016, by electronic mail to the following:
`Back-up Counsel for LG Electronics, Inc.
`
`Back-up Counsel for LG Electronics, Inc.
`
`Rajeev Gupta
`Reg. No. 55,873
`Finnegan, Henderson, Farabow, Garrett &
`Dunner, L.L.P.
`901 New York Avenue, N.W.
`Washington, D.C. 20001-4413
`Tel: (202) 408-4000
`Fax: (202) 408-4400
`Email:
`LGE_Finnegan_PUMAIPR@finnegan.com
`
`Back-up Counsel for HTC Corporation
`Joseph A. Micallef
`Reg. No. 39,772
`Sidley Austin LLP
`1501 K Street, N.W.
`Washington, DC 20005
`Tel: (202) 736-8492
`Email: jmicallef@sidley.com
`
`Darren M. Jiron
`Reg. No. 45,777
`Finnegan, Henderson, Farabow, Garrett &
`Dunner, L.L.P.
`11955 Freedom Drive
`Reston, VA 20190-5675
`Tel: (571) 203-2700
`Fax: (202) 408-4400
`Email:
`LGE_Finnegan_PUMAIPR@finnegan.com
`
`Back-up Counsel for HTC Corporation
`Stephen M. Everett
`Reg. No. 30,050
`Sidley Austin LLP
`555 California Street, Suite 2000
`San Francisco, CA 94104
`Tel: (415) 772-7482
`Email: Stephen.everett@sidley.com
`
`Lead Counsel for Samsung Electronics
`
`Back-up Counsel for Samsung Electronics
`
`Naveen Modi
`Reg. No. 46,224
`Paul Hastings LLP
`875 15th Street NW
`Washington, DC 20005
`Tel: (202) 551-1990
`Fax: (202)551-0490
`Email: Samsung-PUMA-
`IPR@paulhastings.com
`
`5
`
`Allan M. Soobert
`Reg. No. 36,284
`Paul Hastings LLP
`875 15th Street NW
`Washington, DC 20005
`Tel: (202) 551-1990
`Fax: (202)551-0490
`Email: Samsung-PUMA-
`IPR@paulhastings.com
`
`
`  
`
`

`
`Case IPR2015-01501
`Patent No. 7,777,753 
`
`
`
`
`
`
`
`
`
`By: /s/ Masood Anjom
`
`Masood Anjom
`
`Reg. No. 62,167
`Attorney for Patent Owner
`Parthenon Unified Memory
`Architecture, LLC
`AHMAD, ZAVITSANOS, ANAIPAKOS,
`ALAVI &MENSING, P.C.
`1221 McKinney Street, Suite 2500
`Houston, TX 77010
`Telephone: 713-655-1101
`
`6
`
`
`Dated: March 4, 2016
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