`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`SL CORPORATION,
`Petitioner,
`
`v.
`
`ADAPTIVE HEADLAMP TECHNOLOGIES, INC.
`Patent Owner
`________________
`
`INTER PARTES REVIEW OF U.S. PATENT NO. 7,241,034
`
`Issue Date: July 10, 2007
`
`Reexamination Certificate Issue Date: June 14, 2013
`
`Title: Automatic Directional Control System for Vehicle Headlights
`
`________________
`
`Inter Partes Review No. IPR2016-00193
`
`MOTION OF SL CORPORATION
`FOR PRO HAC VICE ADMISSION OF ADAM P. SAMANSKY
`
`
`
`I.
`
`Statement of Precise Relief Requested
`
`Petitioner SL Corporation (“SL”) respectfully requests that the Board admit
`
`Adam P. Samansky pro hac vice in this proceeding under 37 C.F.R. § 42.10(c).
`
`II.
`
`Statement of Facts Showing Good Cause for the Board to Recognize
`Counsel Pro Hac Vice during the Proceeding
`
`Pursuant to 37 C.F.R. § 42.10(c), the Board may admit counsel pro hac vice
`
`for good cause, subject to any other conditions that the Board may require, so long
`
`as lead counsel is a registered practitioner. Good cause includes when “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).
`
`This application satisfies the requirements of Section 42.10(c):
`
`1.
`
`Lead counsel, Peter J. Cuomo, the undersigned, is a registered
`
`Practitioner. Currently listed back-up counsel, Kongsik Kim and Serge Subach,
`
`are also registered practitioners.
`
`2.
`
`Pro Hac Vice Applicant, Mr. Adam P. Samansky, is an experienced
`
`litigator and has an established familiarity with the subject matter at issue in this
`
`proceeding, as shown in his accompanying Declaration dated June 20, 2016
`
`(“Samansky Decl.”), Exhibit 1028. That declaration shows that Mr. Samansky
`
`possesses a legal and technical background related to the subject matter of this
`
`proceeding. Samansky Decl. ¶¶ 4-5. He is also directly familiar with U.S. Patent
`
`2
`
`
`
`No. 7,241,034 (“the ‘034 patent”), its prosecution history, and the prior art
`
`references that are the subject of this inter partes review proceeding. Id. ¶¶ 6-7.
`
`3.
`
`Mr. Samansky is admitted, pro hac vice, and is lead trial counsel in
`
`the underlying litigation before the U.S. District Court for the District of Delaware,
`
`Case No. 1:15-cv-0565. Mr. Samansky was substantially involved with the
`
`preparation of the Petition filed in this proceeding. Id. ¶ 7. In particular, he
`
`worked on technical and strategic matters pertaining to the instant Petition and
`
`now-instituted IPR proceeding. Id. Mr. Samansky anticipates being significantly
`
`involved in the deposition and trial phase of this proceeding. Id.
`
`4.
`
`Mr. Samansky is a member in good standing of the Bar of the
`
`Commonwealth of Massachusetts and the Bar of the State of New York. His
`
`Massachusetts Bar membership is 661123. And his New York Bar membership is
`
`493582. Id. ¶ 2. He is admitted to practice before the Supreme Court of the
`
`United States, the United States Courts of Appeals for the Federal, First, Fourth,
`
`Sixth, and Ninth Circuits, and the United States District Court for the District of
`
`Massachusetts. Id.
`
`5.
`
`In his declaration, Mr. Samansky also attests to each of the items
`
`referenced in the “Order – Authorizing Motion for Pro Hac Vice Admission – 37
`
`C.F.R. § 42.10” in IPR2013-00639 (Paper No. 7).
`
`3
`
`
`
`For the foregoing reasons, Patent Owner SL Corporation respectfully
`
`requests that the Board admit Adam P. Samansky pro hac vice in this proceeding.
`
`Respectfully submitted,
`
`SL CORPORATION,
`
`By its attorneys,
`
`/Peter J. Cuomo /
`Peter J. Cuomo (Reg. No. 54,481)
`Kongsik Kim (Reg. No. 63,867)
`Serge Subach (Reg. No. 74,652)
`MINTZ, LEVIN, COHN, FERRIS,
`GLOVSKY AND POPEO, P.C.
`One Financial Center
`Boston, MA 02111
`Phone: (617) 542-6000
`Fax: (617) 542-2241
`
`Counsel for Petitioner
`SL Corporation
`
`4
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Motion of SL
`
`Corporation for Pro Hac Vice Admission of Adam P. Samansky was served on
`
`June 24, 2016 by email to:
`
`Brett M. Pinkus
`FRIEDMAN, SUDER & COOKE
`604 E. Fourth Street, Suite 200
`Fort Worth, TX 76102
`pinkus@fsclaw.com
`
`AND
`
`hermesch@fsclaw.com
`klein@fsclaw.com
`putnam@fsclaw.com
`dunn@fsclaw.com
`
`/Peter J. Cuomo /
`By:
`Peter J. Cuomo, Reg. No. 54,481
`Lead Counsel for Petitioner
`
`5
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