IPR2016-00349
`Motion for Admission Pro Hac Vice
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`T-MOBILE US, INC. and T-MOBILE USA, INC. and
`CELLCO PARTNERSHIP d/b/a VERIZON WIRELESS
`Petitioners
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`v.
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`ADVANCED MEDIA NETWORKS, LLC,
`Patent Owner
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`Case IPR2016-00349
`Patent No. 5,960,074
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`T-MOBILE US, INC. AND T-MOBILE USA, INC.’S UNOPPOSED
`MOTION FOR ADMISSION PRO HAC VICE
`UNDER 37 C.F.R. § 42.10(C)
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`
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`Mail Stop: Patent Board
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Motion for Admission Pro Hac Vice
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`T-MOBILE US, INC. and T-MOBILE USA, INC. and
`CELLCO PARTNERSHIP d/b/a VERIZON WIRELESS
`Petitioners
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`v.
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`ADVANCED MEDIA NETWORKS, LLC,
`Patent Owner
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`Case IPR2016-00349
`Patent No. 5,960,074
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`T-MOBILE US, INC. AND T-MOBILE USA, INC.’S UNOPPOSED
`MOTION FOR ADMISSION PRO HAC VICE
`UNDER 37 C.F.R. § 42.10(C)
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`
`
`Mail Stop: Patent Board
`Patent Trial and Appeal Board
`United States Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`IPR2016-00349
`Motion for Admission Pro Hac Vice
`T-Mobile US, Inc. and T-Mobile USA, Inc. (together, “T-Mobile” or
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`“Petitioner”) respectfully requests that the Board recognize Asim Bhansali, Esq., as
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`counsel pro hac vice during this proceeding.
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`I.
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`BACKGROUND
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`T-Mobile files this Motion for Admission Pro Hac Vice in accordance with
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`the Notice of Filing Date Accorded to Petition and Time for Filing Patent Owner
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`Preliminary Response (Paper 4), mailed December 22, 2015, and in accordance
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`with 37 C.F.R. § 42.10(c) and the Order – Authorizing Motion for Pro Hac Vice
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`Admission in Case IPR2013-00639, Paper 7.
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`II. THE CONDITIONS FOR PRO HAC VICE ADMISSION ARE MET
`HERE
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`The conditions outlined in 37 C.F.R. § 42.10(c) and the Order – Authorizing
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`Motion for Pro Hac Vice Admission in Case IPR2013-00639, Paper 7 are met
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`here.
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`First, Lead Counsel for Petitioner (Leo Lam, Reg. No. 38,528) is registered
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`to practice before the Board. See 37 C.F.R. § 41.10(c).
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`Second, good cause exists to permit Mr. Bhansali to be admitted pro hac
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`vice for this matter. Mr. Bhansali has established familiarity with the subject
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`matter at issue in this proceeding, including extensive knowledge of the printed
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`prior art submitted in the instant Petition and related matters. See id. Mr. Bhansali
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`is a highly experienced patent-litigation attorney, and has handled numerous patent
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`1082363
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`IPR2016-00349
`Motion for Admission Pro Hac Vice
`litigations in various federal district courts and the U.S. International Trade
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`Commission. He has substantial experience litigating patents in
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`telecommunications fields, and relating to location technology in particular. Mr.
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`Bhansali has previously represented and is currently representing T-Mobile in
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`several other patent matters concerning wireless telecommunications generally,
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`and location and networking protocols specifically. Mr. Bhansali has also
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`represented other clients in patent matters involving wireless telecommunications.
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`As part of his representation of T-Mobile in this and other matters, he has analyzed
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`the relevant technologies in depth both independently and in consultation with
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`expert witnesses and engineers. Mr. Bhansali has also performed extensive
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`reading and research into related technical matters.
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`Mr. Bhansali also has substantial experience with U.S. Patent 5,960,074.
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`He is lead trial counsel for T-Mobile in the federal district court litigation
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`concerning the ’074 Patent. He participated in the drafting of the Petition filed in
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`this proceeding. In addition, Mr. Bhansali has served as counsel pro hac vice in
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`other IPR proceedings as well.
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`Counsel for Petitioner understands that Patent Owner does not oppose this
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`motion.
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`III. AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
`Petitioner T-Mobile’s Motion for Pro Hac Vice Admission is accompanied
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`IPR2016-00349
`Motion for Admission Pro Hac Vice
`by an Affidavit of Mr. Bhansali.
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`IV. CONCLUSION
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`Therefore, Petitioner T-Mobile respectfully requests that the Board
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`recognize Mr. Bhansali as counsel pro hac vice during this proceeding.
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`Dated: August 11, 2016
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`Respectfully submitted,
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`KEKER & VAN NEST LLP
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`By: /s/ Leo Lam, # 38,528
`Leo Lam (Reg. No. 38,528)
`633 Battery Street
`San Francisco, CA 94111
`Phone: 415-391-5400
`Fax: 415-397-7188
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`1082363
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`IPR2016-00349
`Motion for Admission Pro Hac Vice
`AFFIDAVIT OF ASIM BHANSALI IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
`I, Asim Bhansali, being duly sworn and upon oath, hereby attest to the
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`following:
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`1.
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`I am a member in good standing of the State Bar of California, as well
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`as the State Bars of New York and Texas, the bars of the United States District
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`Courts for the Northern, Central, and Eastern Districts of California, the Northern,
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`Western, and Southern Districts of Texas, the Southern District of New York, the
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`District of Colorado, and the United States Courts of Appeals for the Third, Fifth,
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`Ninth, and Federal Circuits.
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`2.
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`I have not been suspended or disbarred from practice before any court
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`or administrative body.
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`3.
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`I have never had an application for admission to practice before any
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`court or administrative body denied.
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`4.
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`No sanction or contempt citation has been imposed against me by any
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`court or administrative body.
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`5.
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`I have read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`6.
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`I will be subject to the USPTO Rules of Professional Conduct set
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`forth in 37 C.F.R. §§ 11.101, et seq., and disciplinary jurisdiction under 37 C.F.R.
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`§ 11.19(a).
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`1082363
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`IPR2016-00349
`Motion for Admission Pro Hac Vice
`I have applied for and been granted permission to appear pro hac vice
`7.
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`in IPR2015-01567 and IPR2015-01573 within the last three years. I am
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`concurrently applying to appear pro hac vice in IPR2016-00347, which also
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`concerns U.S. Patent 5,960,074.
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`8.
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`I am lead trial counsel for T-Mobile in the district court litigation
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`concerning U.S. Patent No. 5,960,074. I am familiar with the subject matter at
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`issue in this proceeding, including the prior art on which Petitioner relies in this
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`matter and U.S. Patent No. 5,960,074. I also participated in the drafting of the
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`Petition already filed in this proceeding. I have reviewed the pertinent issues of
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`claim construction that have been briefed in this proceeding.
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`9.
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`I am an experienced patent litigator and have handled complex
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`litigation in both federal and state court. I have litigated patents relating to mobile
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`telephone technology, and particularly wireless networking. I have previously and
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`am currently representing T-Mobile in several other patent matters concerning
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`wireless telecommunications generally, and wireless networking specifically. I
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`have also represented other clients in patent cases involving wireless
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`telecommunications technology.
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`10. As part of my representation of T-Mobile in the district court
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`litigation and in connection with the drafting of the Petition, I have discussed the
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`IPR2016-00349
`Motion for Admission Pro Hac Vice
`relevant technologies in depth with expert witnesses and engineers. I have also
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`performed my own extensive reading and research into related technical matters.
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`I declare under penalty of perjury that the foregoing is true and correct and
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`that this declaration was executed on August 11, 2016, in San Francisco,
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`California.
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`By: /s/ Asim Bhansali
`ASIM BHANSALI
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`1082363
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`IPR2016-00349
`Motion for Admission Pro Hac Vice
`CERTIFICATE OF SERVICE ON PATENT OWNER
`UNDER 37 C.F.R. § 42.105(A)
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`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies
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`that, on the 11th day of August, 2016, a complete and entire copy of this Motion
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`for Admission Pro Hac Vice, was provided to the Patent Owner was provided to
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`the Patent Owner by emailing a copy of the same to the following attorneys of
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`record for the Patent Owner:
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`Antonio Papageorgiou
`ap@msf-law.com
`Seth H. Ostrow
`sho@msf-law.com
`MEISTER SEELIG & FEIN LLP
`125 Park Ave., 7th Floor
`New York, NY 10017
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`and a copy to patents@msf-law.com.
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`/s/ Leo Lam, # 38,528
`Leo Lam (Reg. No. 38,528)
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`1082363
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