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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
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`v.
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`ELBRUS INTERNATIONAL LIMITED
`Patent Owner
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`Case IPR2015-01524
`Patent No. 6,366,130
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`PETITIONER’S MOTION FOR SUBSTITUTION OF LEAD COUNSEL
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`I.
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`IPR2015-01524
`US Patent No. 6,366,130
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`STATEMENT OF RELIEF REQUESTED
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`Pursuant to 37 C.F.R. § 42.10, Petitioner respectfully requests that the Board
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`authorize withdrawal of its current lead counsel, Steven L. Park, and substitute
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`with current back-up counsel, Naveen Modi.
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`II. REASONS FOR GRANTING THE MOTION
`In a July 14, 2016 e-mail to the Board, Petitioner requested authorization to
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`file a motion to withdraw lead counsel. In the e-mail, Petitioner indicated that
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`Steven L. Park, who is currently listed as lead counsel for Petitioner, is no longer
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`with the law firm of Paul Hastings, LLP. Petitioner stated that it will substitute
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`Naveen Modi as lead counsel for Mr. Park, and will appoint another back-up
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`counsel. On July 15, 2016, the Board authorized Petitioner to file a motion to
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`withdraw lead counsel. Paper 15 at 2.
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`Petitioner is filing concurrently herewith updated mandatory notices
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`appointing additional back-up counsel, Joseph E. Palys and Joseph J. Rumpler.
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`Upon granting of this motion, Petitioner will file updated mandatory notices to
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`reflect that Naveen Modi, who is currently listed as back-up counsel, is lead
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`counsel.
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`The parties have met and conferred regarding this motion.. Patent Owner
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`has indicated that it does not oppose the motion.
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`III. CONCLUSION
`Petitioner respectfully requests that the Board grant its motion to authorize
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`IPR2015-01524
`US Patent No. 6,366,130
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`withdrawal of counsel and permit substitution of counsel.
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`Respectfully submitted,
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`By: /Naveen Modi/
`Naveen Modi (Reg. No. 46,224)
`Paul Hastings LLP
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`Counsel for Samsung Electronics Co., Ltd.
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`Dated: September 26, 2016
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`2
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`IPR2015-01524
`US Patent No. 6,366,130
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), I certify that I caused to be served on the
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`counsel for Patent Owner a true and correct copy of the foregoing Petitioner’s
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`Motion For Substitution Of Lead Counsel by electronic means on the date below at
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`the following address of record:
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`Clifford H. Kraft (clifflaw@att.net)
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`Arthur A. Gasey (gasey@nshn.com)
`Joseph N. Hosteny (hosteny@hosteny.com)
`Olivia T. Luk (oluk@nshn.com)
`Christopher W. Niro (cniro@nshn.com)
`Ashley E. LaValley (alavalley@nshn.com)
`NIRO, HALLER & NIRO
`181 W. Madison, Suite 4600
`Chicago, IL 60602
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`Respectfully submitted,
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`Dated: September 26, 2016
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`By: /Naveen Modi/
`Naveen Modi (Reg. No. 46,224)
`Paul Hastings LLP
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`Counsel for Petitioner
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