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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`PLAID TECHNOLOGIES INC.
`Petitioner
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`v.
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`YODLEE, INC.
`Patent Owner
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`Case IPR2016-00273
`Patent 6,317,783
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`PATENT OWNER’S
`MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. § 42.10(c)
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`EXHIBIT LIST
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`Case IPR2016-00273
`Attorney Docket No: 12233-0047IP1
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`Exhibit No. Description
`2001
`ESPN Insider: Benefits, WayBackMachine, June 22, 2001
`Declaration of David Barkan in Support of Motion for Pro Hac
`2002
`Vice Admission
`Declaration of Matthew McCullough in Support of Motion for
`Pro Hac Vice Admission
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`2003
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`ii
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`Case IPR2016-00273
`Attorney Docket No: 12233-0047IP1
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`Pursuant to 37 C.F.R. § 42.10(c), the Patent Owner (“Yodlee, Inc”)
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`respectfully requests that the Board recognize Matthew McCullough as counsel
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`pro hac vice in this proceeding. Patent Owner seeks the counsel of Matthew
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`McCullough due to his familiarity with the substantive and technical issues
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`involved in this proceeding, which he gained in the course of working on this IPR
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`and another CBM petition involving this same patent (CBM2016-00045). This
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`motion is authorized by the Notice of Filing Date Accorded to Petition and Time
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`for Filing Patent Owner Preliminary Response that was mailed on December 11,
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`2015.
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`Statement of Facts
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`Mr. McCullough is a patent litigation attorney with experience representing
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`clients in patent cases involving a wide range of products and technology,
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`including cloud-based enterprise software, video game systems, data compression
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`algorithms, mobile device software and hardware, and other consumer products. .
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`Mr. McCullough has tried intellectual property cases before juries in a number of
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`US district courts as well as before the US International Trade Commission. He
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`has a background in computer engineering and in addition to patent litigation, Mr.
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`McCullough also assists clients with trade secret litigation, patent due diligence,
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`trade secret due diligence, and other non-litigation related patent analysis. Patent
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`1
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`Case IPR2016-00273
`Attorney Docket No: 12233-0047IP1
`Owner Yodlee, Inc. submits as evidence Exhibit A, Matthew McCullough’s
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`biography.
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`Mr. McCullough also has particular experience and familiarity with the
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`substantive and technical issues involved in this inter partes review proceeding.
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`Mr. McCullough has assisted Yodlee, Inc. with a number of other inter partes
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`review and covered business method review proceedings, including one
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`(CBM2016-00045) that concerns the patent at issue in the present matter, U.S.
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`Patent No. 6,317,783. Yodlee, Inc. has invested significant financial resources on
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`each of the matters on which Mr. McCullough has worked and what is more, they
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`have come to trust and respect Mr. McCullough, so that they understandably wish
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`to continue working with him on the present matter.
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`1. Affidavit of Individual Seeking to Appear
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`This Motion for Pro Hac Vice Admission is accompanied by a Declaration
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`of Matthew McCullough as required by the Order Authorizing Motion for Pro Hac
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`Vice mailed December 11, 2015.
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`Accordingly, Patent Owner submits that there is good cause under 37 C.F.R.
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`§ 42.10(c) for the Board to recognize Matthew McCullough as counsel Pro Hac
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`Vice during this proceeding.
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`Case IPR2016-00273
`Attorney Docket No: 12233-0047IP1
`Respectfully submitted,
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`/David M. Hoffman/
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` David M. Hoffman
`Reg. No. 54,174
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`Fish & Richardson P.C.
`3200 RBC Plaza
`60 South Sixth Street
`Minneapolis, MN 55402
`T: (512) 226-8154
`F: (512) 320-8935
`Email: IPR12233-0047IP1@fr.com
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`Counsel for Patent Owner
`Yodlee, Inc.
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`Date: July 7, 2016
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`Case IPR2016-00273
`Attorney Docket No: 12233-0047IP1
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 CFR §§ 42.6(e)(4), the undersigned certifies that on July 7,
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`2016, a complete and entire copy of this Patent Owner’s Motion for Pro Hac Vice
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`Admission was provided via electronic service to the Petitioner, by serving the
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`correspondence address of record as follows:
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`Brian Buroker
`Omar Amin
`Gibson, Dunn & Crutcher LLP
`1050 Connecticut Avenue, N.W.
`Washington, D.C. 20036-5306
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`E-mail: bburoker@gibsondunn.com
` oamin@gibsondunn.com
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`/Jessica K. Detko/
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`Jessica K. Detko
`Fish & Richardson P.C.
`60 South Sixth Street, Suite 3200
`Minneapolis, MN 55402
`(612) 337-2516
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`4