`
`
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`
`LAM RESEARCH CORP.,
`Petitioner,
`
`v.
`
`DANIEL L. FLAMM,
`Patent Owner.
`___________________
`
`Case IPR2015-01764
`Patent No. RE 40,264 E
`___________________
`
`
`
`
`
`LAM RESEARCH CORPORATION’S REVISED UNOPPOSED MOTION
`FOR ADMISSION PRO HAC VICE OF TALIN GORDNIA
`UNDER 37 C.F.R. § 42.10
`
`
`
`
`
`
`
`
`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`8687641
`
`
`
`
`
`
`
`
`Case IPR2015-01764
`Patent No. RE 40,264 E
`
`
`I.
`
`RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.10(c) and the Board’s “Notice of Filing Date
`
`Accorded to the Petition and Time for Filing Patent Owner’s Preliminary
`
`Response” entered August 27, 2015, Paper 3, granting authorization to file motions
`
`for pro hac vice admission under 37 C.F.R. § 42.10(c), Petitioner Lam Research
`
`Corporation requests that the Board admit Talin Gordnia pro hac vice in this
`
`proceeding.
`
`Petitioner submitted a motion for pro hac vice admission of Talin Gordnia
`
`(Paper 11) on May 9, 2016, but inadvertently submitted the motion as the
`
`declaration in support of the motion (Ex. 1014). The Board has authorized the
`
`Petitioner to resubmit the correct declaration in its Order (Paper 13) issued on
`
`May 17, 2016. Petitioner is herein filing this revised motion, accompanied by the
`
`required declaration.
`
`II.
`
`STATEMENT OF FACTS
`
`Pursuant to 37 C.F.R. § 42.10(c), the Board
`
`may recognize counsel pro hac vice during a proceeding
`upon a showing of good cause, subject to the condition
`that lead counsel be a registered practitioner and to any
`other conditions as the Board may impose. For
`example, where the lead counsel is a registered
`practitioner, a motion to appear pro hac vice by counsel
`
`8687641
`
`
`- 1 -
`
`
`
`
`
`Case IPR2015-01764
`Patent No. RE 40,264 E
`
`
`who is not a registered practitioner may be granted upon
`showing that counsel is an experienced litigating
`attorney and has an established familiarity with the
`subject matter at issue in the proceeding.
`
`37 C.F.R. § 42.10(c). The facts, supported by the Declaration of Talin Gordnia in
`
`Support of Motion for Admission Pro Hac Vice (“Gordnia Decl.”, Ex. 1014),
`
`establish good cause to admit Talin Gordnia pro hac vice in this proceeding.
`
`1.
`
`Lead counsel Michael R. Fleming is a registered practitioner and is
`
`experienced in inter partes proceedings before the USPTO.
`
`2.
`
`Backup counsel Samuel Lu
`
`is a registered practitioner and
`
`experienced in inter partes proceedings before the USPTO.
`
`3.
`
`Talin Gordnia is an experienced litigating attorney. Ms. Gordnia has
`
`extensive experience in patent law and has been litigating patent cases for over five
`
`(5) years. Gordnia Decl. ¶ 9. Ms. Gordnia is a member in good standing of the
`
`California State Bar, with no suspensions or disbarments from practice, nor any
`
`application for admission to practice denied, nor any sanctions or contempt
`
`citations. Ms. Gordnia is also admitted to practice before the United States
`
`District Courts for the Central District of California and Northern District of
`
`California.
`
`8687641
`
`
`- 2 -
`
`
`
`
`
`Case IPR2015-01764
`Patent No. RE 40,264 E
`
`
`4. Ms. Gordnia has familiarity with the subject matter at issue in this
`
`proceeding.
`
`5. Ms. Gordnia has read and will comply with the Office Patent Trial
`
`Practice Guide and the Board’s Rules for Practice for Trials set forth in Title 42 of
`
`the C.F.R., and she agrees to be subject to the USPTO Code of Professional
`
`Responsibility set forth in 37 C.F.R. §§ 11.101 et seq., and to disciplinary
`
`jurisdiction under 37 C.F.R. § 11.19(a).
`
`III. ANALYSIS
`The facts contained in the Statement of Facts above, and contained in the
`
`Gordnia Declaration, establish that there is good cause to admit Talin Gordnia pro
`
`hac vice in this proceeding under 37 C.F.R. § 42.10. Lead and backup counsel are
`
`registered practitioners, Ms. Gordnia is an experienced litigating attorney, and Ms.
`
`Gordnia has an established familiarity with the subject matter at issue in the
`
`proceeding.
`
`IV. NO OPPOSITION TO THIS MOTION
`Petitioner has confirmed with Patent Owner that they do not oppose the
`
`present motion.
`
`V. CONCLUSION
`For the foregoing reasons, Lam Research Corporation respectfully requests
`
`that the Board admit Talin Gordnia pro hac vice in this proceeding.
`
`8687641
`
`
`- 3 -
`
`
`
`
`
`Case IPR2015-01764
`Patent No. RE 40,264 E
`
`
`Dated: May 17, 2016
`
`
`
`
`
`Respectfully submitted,
`
`By:
`
` /s/Michael R. Fleming/
` Michael R. Fleming
`
`
`
`Michael R. Fleming (Reg. No. 67,633)
`Samuel Lu (Reg. No. 40,707)
`Talin Gordnia (Pro hac vice to be requested)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067-4276
`Telephone: (310) 277-1010
`Fax: (310) 203-7199
`Email: LamFlammIPR@irell.com
`Attorneys for Petitioner,
`Lam Research Corporation
`
`8687641
`
`
`- 4 -
`
`
`
`
`
`Case IPR2015-01764
`Patent No. RE 40,264 E
`
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on May 17, 2016,
`
`a copy of the foregoing document and supporting Declaration (Ex. 1014) were
`
`served, by electronic mail, as agreed to by the parties, upon the following:
`
`Lead Counsel for Patent Owner
`DANIEL L. FLAMM
`Christopher Frerking
`chris@ntknet.com
`Registration No. 42,557
`174 Rumford Street
`Concord, New Hampshire 03301
`Telephone: (603) 706-3127
`
`
`
`
`Back-up Counsel for Patent Owner
`DANIEL L. FLAMM
`George C. Summerfield
`summerfield@stadheimgrear.com
`(To be admitted Pro Hac Vice)
`STADHEIM & GREAR, LTD.
`400 N. Michigan Ave., Ste. 2200
`Chicago, Illinois 60611
`Telephone: (312) 755-4400
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
` /s/ Susan M. Langworthy/
` Susan M. Langworthy
`
`
`
`
`
`
`
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
