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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`_______________
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`_______________
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`COSTCO WHOLESALE CORPORATION,
`Petitioner,
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`v.
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`ROBERT BOSCH LLC,
`Patent Owner.
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`_______________
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`
`
`Case IPR2016-00039
`Patent 7,228,588
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`_______________
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`
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`PETITIONER’S MOTION FOR ADMISSION
`PRO HAC VICE OF JAMES W. DABNEY
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`IPR 2016-00039
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE OF JAMES W. DABNEY
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`Pursuant to 37 C.F.R. § 42.10(c), Petitioner Costco Wholesale Corporation
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`
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`respectfully requests that the Board admit James W. Dabney pro hac vice as co-
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`counsel for the Petitioner in this proceeding. The following facts are supported by
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`the Declaration of James W. Dabney (Ex. 1023), submitted herewith:
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`1. Mr. Dabney is a member in good standing of the Bars of the States of
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`New York and New Jersey and has extensive experience with patent
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`law. Ex. 1023 ¶¶ 3-4; see also Ex. 1023 ¶¶ 6-8.
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`2. Mr. Dabney is lead trial counsel for the Petitioner in Robert Bosch
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`LLC v. Alberee Products, Inc., et al., No. 12-574-LPS (D. Del.) (the
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`“Delaware Action”), in which the Respondent is asserting against
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`Petitioner the same patent which is the subject of this proceeding. Ex.
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`1023 ¶ 5.
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`3. As a result of his representation of Petitioner in the Delaware Action,
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`Mr. Dabney has deep familiarity with the factual and legal issues that
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`are raised in this proceeding. Ex. 1023 ¶ 5.
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`4. Mr. Dabney has read and will comply with the Office Patent Trial
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`Practice Guide and the Board’s Rules of Practice for Trials, as set
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`forth in Part 42 of 37 C.F.R. and agrees to be subject to the United
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`States Patent and Trademark Rules of Professional Conduct set forth
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`Page 2
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`
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`IPR 2016-00039
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE OF JAMES W. DABNEY
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`
`
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`in 37 C.F.R. §§ 11.101 et seq. and disciplinary jurisdiction under 37
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`C.F.R. § 11.19(a). Ex. 1023 ¶¶ 10-11.
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`For the foregoing reasons, good cause exists to admit Mr. Dabney pro hac
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`vice in this inter partes review proceeding. It would be a hardship on Petitioner if
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`Mr. Dabney were not able to act as co-counsel and participate fully in the conduct
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`of this proceeding.
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`
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`WHEREFORE, Petitioner respectfully submits
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`that
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`this Motion for
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`Admission Pro Hac Vice of James W. Dabney be granted.
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`
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`Dated: July 1, 2016
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`Respectfully submitted,
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`/Stefanie M. Lopatkin/
`Stefanie M. Lopatkin
`Registration No. 74,312
`Hughes Hubbard & Reed LLP
`One Battery Park Plaza
`New York, NY 10004
`Stefanie.lopatkin@hugheshubbard.com
`(212) 837-6393
`Attorney for Petitioner
`TC Heartland LLC
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`Page 3
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`IPR 2016-00039
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE OF JAMES W. DABNEY
`
`
`CERTIFICATE OF SERVICE
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`
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`I hereby certify that on this 1st day of July, 2016, the foregoing Petitioner’s Motion
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`for Admission Pro Hac Vice of James W. Dabney and Exhibit 1023 thereto, were
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`served in their entirety by email on the attorneys of record for Patent Owner:
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`• Patrick R. Colsher (patrick.colsher@shearman.com)
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`• Mark A. Hannemann (mark.hannemann@shearman.com)
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`/Stefanie M. Lopatkin/
`Stefanie M. Lopatkin
`Registration No. 74,312
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`70801725
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`Page 4
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