`___________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________
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`SIRIUS XM RADIO INC.,
`Petitioner,
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`v.
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`DRAGON INTELLECTUAL PROPERTY, LLC,
`Patent Owner
`___________
`
`No. IPR2015-01735
`U.S. Patent No. 5,930,444
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`MOTION TO WITHDRAW AS COUNSEL
`PURSUANT TO 37 C.R.F. 42.10(E)
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`I.
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`Statement of Precise Relief Requested.
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`Pursuant to 37 C.F.R. § 42.10 and authorization provided by the Patent Trial
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`and Appeal Board (“the Board”) on November 10, 2015, Patent Owner Dragon
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`Intellectual Property, LLC (“Dragon”) respectfully requests that the Board
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`authorize withdrawal of its current counsel Jason S. Angell and Robert E. Freitas
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`of Freitas Angell & Weinberg LLP.
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`II.
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`Statement of Facts Showing Good Cause for the Board to Authorize
`Withdrawal of Counsel.
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`On August 25, Patent Owner Dragon appointed Jason S. Angell and Robert
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`E. Freitas as its attorneys in the above-captioned inter partes review. Patent
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`Owner Dragon requests that current designated counsel, Jason S. Angell and
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`Robert E. Freitas, be allowed to withdraw from the present proceeding, and new
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`counsel, Kai Zhu, be designated lead counsel to represent Dragon in this
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`proceeding. Dragon intends to appoint new counsel as follows:
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`Kai Zhu (Reg. No. 64,586)
`60 Cody Ln
`Los Altos, CA 94022
`Telephone: (650) 999-0172
`Facsimile: (928) 569-1639
`kz@dragonipllc.com
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`New counsel meets the requirements of 37 C.F.R. § 42.10(c) as lead counsel
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`and is a registered practitioner. In addition Dragon’s proposed lead counsel has
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`read and intends to comply with the Office Patent Trial Practice Guide and the
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`Board’s Rules of Practice for Trials, as set forth in Part 42 of the C.F.R. Dragon
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`has advised the Board that the withdrawal and change in lead counsel will not
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`affect the orderly progress of this proceeding.
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`Patent Owner Dragon respectfully requests that the Board grant its motion to
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`authorize withdrawal of counsel. Upon grant of this motion, current counsel for
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`Dragon will promptly file an updated mandatory notice. Dragon has herewith filed
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`By:/s/Jason S. Angell
`Jason S. Angell
`Reg. No. 51408
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`
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`
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`a new Power of Attorney for Mr. Zhu.
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`
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`Dated: November 11, 2015
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`-1-
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`CERTIFICATE OF SERVICE
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`It is certified that a copy of the foregoing Power of Attorney has been served
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`on Petitioner via electronic mail transmission addressed to the persons at the
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`addresses below:
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`Jonathan S. Caplan (Reg. No. 38,094)
`James Hannah (Reg. No. 56,369)
`Mark A. Baghdassarian
`KRAMER LEVIN NAFTALIS & FRANKEL LLP
`jcaplan@kramerlevin.com
`jhannah@kramerlevin.com
`mbaghdassarian@kramerlevin.com
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`Dated: November 11, 2015
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`By:/s/Jason S. Angell
`Jason S. Angell
`Reg. No. 51408
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`-2-