`U.S. Patent No. 8,266,432
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`UNITED SERVICES AUTOMOBILE ASSOCIATION,
`
`Petitioner
`
`v.
`
`NADER ASGHARI-KAMRANI and KAMRAN ASGHARI-KAMRANI,
`
`Patent Owners
`
`U.S. PATENT NO. 8,266,432
`
`Case IPR2015-01842
`
`MOTION FOR WITHDRAWAL BY COUNSEL
`
`
`
`I. 37 C.F.R. §42.10 – STATEMENT OF RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.10, present Counsel for Patent Owners, Jae Youn
`
`Kim, Harold L. Novick, and Sang Ho Lee at Novick, Kim & Lee, PLLC, respectfully
`
`request that the Board authorize their withdrawal as counsel for Patent Owners
`
`pursuant to 37 C.F.R. §41.5(c) and §11.116(a)(3). Counsel has been advised that
`
`Patent Owners have selected new counsel Reece Nienstadt at Mei & Mark LLP as
`
`lead counsel, and Krystyna Colantoni, and Lei Mei at Mei & Mark LLP as backup
`
`counsel in this matter.
`
`
`
` IPR2015-01842
`U.S. Patent No. 8,266,432
`
`II. STATEMENT SHOWING GOOD CAUSE FOR THE BOARD TO
`AUTHORIZE WITHDRAWAL AND SUBSTITUTION OF COUNSEL
`
`
`On September 23, 2015, Patent Owners submitted their Mandatory Notice
`
`Under 37 C.F.R. §§ 42.8(a)(2), appointing Jae Youn Kim, Harold L. Novick, and
`
`Sang Ho Lee at Novick, Kim & Lee, PLLC as their counsel in the above-captioned
`
`inter partes review. Patent Owners now desire that the originally designated counsel
`
`be withdrawn from the present proceeding, and their new counsel, Reece Nienstadt,
`
`Krystyna Colantoni, and Lei Mei, be designated as counsel to represent Patent
`
`Owners in this proceeding.
`
`This case is presently in a quiescent state since Patent Owners filed a
`
`Preliminary Response pursuant to 35 U.S.C. 313 and 37 C.F.R. §42.107 on
`
`December 10, 2015 and the decision on the institution of a Post Grant Review is now
`
`pending before the Board.
`
`It is submitted that reasonable steps have been taken by the original counsel
`
`for the Patent Owners such that withdrawal can be accomplished without material
`
`adverse effect on the interests of the Patent Owners. Further, it is believed that
`
`granting this motion will not hinder the economy, the integrity of the patent system,
`
`the efficient administration of the Office, or the ability of the Office to timely
`
`complete this proceeding. See 35 U.S.C. § 316(b).
`
`
`
`
`
` IPR2015-01842
`U.S. Patent No. 8,266,432
`
`III. THE BOARD HAS AUTHORIZED THIS WITHDRAWAL
`
`On January 12, 2016, the Board has authorized counsel for patent owners to
`
`file a Motion to Withdraw as counsel and substitute new counsel.
`
`IV. CONCLUSION
`
`Accordingly, counsel for Patent Owners respectfully requests that the Board
`
`grant this motion of withdrawal of counsel and permit substitution of counsel. Upon
`
`the granting of this motion, it is believed that new counsel for Patent Owners will
`
`promptly file Amended Patent Owner’s Mandatory Notices and a Substitute Power
`
`of Attorney.
`
`January 13, 2016
`
`
`
`
`
`
`
`Respectfully submitted,
`
`By: / J a e Y o u n K i m /
`Jae Youn Kim, Reg. No. 69,215
`Lead Counsel
`Novick, Kim & Lee, PLLC
`1604 Spring Hill Rd. Suite 320
`Vienna, VA 22182
`Telephone: 703-546-8554
`
`
`
`CERTIFICATE OF SERVICE
`
` IPR2015-01842
`U.S. Patent No. 8,266,432
`
`I hereby certify that a copy of the foregoing MOTION FOR WITHDRAWAL
`
`BY COUNSEL is being served on January 13, 2016 via email on the following:
`
`Counsel for Petitioner:
`
`Michael Zoppo, Lead Counsel
`zoppo@fr.com
`
`Thomas Rozylowicz, Back-up Counsel
`Ipr36137-0007ip1@fr.com
`
`
`
`Patent Owners:
`
`Nader Asghari-Kamrani and Kamran Asghari-Kamrani
`kamrani@delphinustechnology.com.
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`By: /Sang Ho Lee/
`
`Sang Ho Lee
`Reg. No. 69,723
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