`_______________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_______________
`HYUNDAI MOTOR COMPANY LTD., HYUNDAI MOTOR AMERICA,
`HYUNDAI MOTOR MANUFACTURING ALABAMA, LLC, KIA MOTORS
`CORPORATION, KIA MOTORS AMERICA, INC.,
`KIA MOTORS MANUFACTURING GEORGIA, INC., NISSAN NORTH
`AMERICA, INC., NISSAN MOTOR CO., LTD., and AMERICAN HONDA
`MOTOR CO., INC.,
`Petitioner,
`v.
`BLITZSAFE TEXAS, LLC,
`Patent Owner.
`_______________
`Case IPR2016-004181
`Patent 8,155,342 B2
`_______________
`
`NISSAN MOTOR CO., LTD. AND NISSAN NORTH AMERICA, INC.’S
`MOTION FOR PRO HAC VICE ADMISSION UNDER 37 C.F.R. § 42.10(c)
`
`
`
`
`
`1 Cases IPR2016-01533, IPR2016-01557, and IPR2016-01560 have been joined
`with this proceeding.
`
`
`
`Petitioners Nissan Motor Co., Ltd. and Nissan North America, Inc.
`
`(collectively “Petitioners”) hereby submit this Motion for Pro Hac Vice admission
`
`for Mr. Michael T. Murphy. Petitioners respectfully move that the Board recognize
`
`Mr. Murphy as counsel pro hac vice during this proceeding pursuant to 37 C.F.R.
`
`§42.10(c).
`
`1. Time for Filing
`
`Petitioners note that this Motion for Pro Hac Vice Admission is being filed
`
`no sooner than twenty-one (21) days after service of the petition. See Unified
`
`Patents, Inc. v. Parallel Iron, LLC, IPR2013-00639, Paper No. 7.
`
`2. Statement of Facts Showing Good Cause for Admission of Counsel Pro
`
`Hac Vice
`
`Petitioners have been authorized to file a motion seeking admission pro hac
`
`vice under 37 C.F.R. 42.10(c). (IPR2016-01560, Paper No. 5). Petitioners’ Lead
`
`and other Back-Up Counsel are registered practitioners: Lead Counsel: David L.
`
`Tarnoff, USPTO Reg. No. 32,383; and Back-Up Counsel: Sean N. Hsu, USPTO
`
`Reg. No. 69,477; and Suzanne E. Konrad, USPTO Reg. No. 60,517.
`
`Mr. Murphy is an experienced patent litigation attorney, and his firm, Global
`
`IP Counselors, LLP, handles a significant amount of patent prosecution work for
`
`Nissan North America, Inc. In particular, Mr. Tarnoff and Mr. Murphy have worked
`
`together to counsel Petitioners on intellectual property issues related to Petitioners’
`
`
`
`business including technologies relating to this proceeding. If admitted, Mr. Murphy
`
`will be involved with the proceeding, including its settlement and termination.
`
`Petitioners wish to apply Mr. Murphy’s knowledge of the subject matter
`
`related to this proceeding, as well as Mr. Murphy’s litigation experience, by
`
`employing him as counsel in this proceeding.
`
`Petitioners respectfully submit that there is good cause for the Board to
`
`recognize Mr. Murphy as counsel pro hac vice during this proceeding.
`
`3. Affidavit of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is supported by an Affidavit of Mr.
`
`Murphy (Ex. 1028).
`
`
`
`
`
`
`
`
`
`Date: February 2, 2017
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
` /David L. Tarnoff/
`
`
`
`David L. Tarnoff
`Reg. No. 32,383
`Global IP Counselors, LLP
`1233 Twentieth St., NW, Suite 600
`Washington, DC 20036
`(202) 292-2209
`dtarnoff@giplaw.com
`Counsel for Petitioners Nissan Motor
` Co., Ltd. and Nissan North America,
` Inc.
`
`
`
`
`
`
`
`
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the attached PETITIONERS’
`
`CORRECTED MOTION FOR PRO HAC VICE ADMISSION UNDER 37 C.F.R. §
`
`42.10(c) and AFFIDAVIT IN SUPPORT OF MOTION FOR PRO HAC VICE
`
`ADMISSION OF MICHAEL T. MURPHY were served on February 2, 2017 upon
`
`the following parties via Express delivery:
`
`Ira M. Marlowe
`BLITZSAFE OF AMERICA, INC.
`33 Honeck Street Englewood, NJ 07631
`
`Courtesy Copies of the attached UPDATED MANDATORY NOTICE were
`
`also served via e-mail to the following parties:
`
`Peter Lambrianakos (Lead Counsel for Patent Owner)
`plambrianakos@brownrudnick.com
`Shahar Harel (Back-up Counsel for Patent Owner)
`sharel@brownrudnick.com
`Vincent Rubino (Back-up Counsel for Patent Owner)
`vrubino@brownrudnick.com
`
`William H. Mandir (Lead Counsel)
`Yoshinari Kishimoto (Back-up Counsel)
`John F. Rabena (Back-up Counsel)
`Fadi N. Kiblawi (Back-up Counsel)
`Margaret M. Welsh (Back-up Counsel)
`toyota@sughrue.com
`
`Joseph Melnik (Lead Counsel)
`jmelnik@jonesday.com
`Joseph Beauchamp (Back-up Counsel)
`jbeauchamp@jonesday.com
`H. Albert Liou (Back-up Counsel)
`aliou@jonesday.com
`
`
`
`Paul R. Steadman (Lead Counsel)
`paul.steadman@dlapiper.com
`Matthew D. Satchwell (Back-up Counsel)
`matthew.satchwell@dlapiper.com
`Gianni Minutoli (Back-up Counsel)
`Gianni.minutoli@dlapiper.com
`Nicholas Panno (Back-up Counsel)
`Nicholas.panno@dlapiper.com
`
`
`
`Dated:
`
`February 2, 2017
`
`
`
` /David L. Tarnoff/
` David L. Tarnoff
`
`
`
`
`
`
`
`
`
`
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