IPR2016-00419
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`PATENT NO. 8,155,342
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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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`TOYOTA MOTOR CORPORATION
`Petitioner
`v.
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`BLITZSAFE TEXAS, LLC
`Patent Owner
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`
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`Patent No. 8,155,342
`Issue Date: April 10, 2012
`Title: MULTIMEDIA DEVICE INTEGRATION SYSTEM
`__________________________________________________________________
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`BLITZSAFE TEXAS, LLC’S MOTION FOR PRO HAC VICE ADMISSION
`OF ALFRED R. FABRICANT PURSUANT TO 37 C.F.R. § 42.10
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`Case No. IPR2016-00419
`__________________________________________________________________
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`PATENT NO. 8,155,342
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`UNITED STATES PATENT AND TRADEMARK OFFICE
`__________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`__________________________________________________________________
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`TOYOTA MOTOR CORPORATION
`Petitioner
`v.
`
`BLITZSAFE TEXAS, LLC
`Patent Owner
`
`
`
`Patent No. 8,155,342
`Issue Date: April 10, 2012
`Title: MULTIMEDIA DEVICE INTEGRATION SYSTEM
`__________________________________________________________________
`
`BLITZSAFE TEXAS, LLC’S MOTION FOR PRO HAC VICE ADMISSION
`OF ALFRED R. FABRICANT PURSUANT TO 37 C.F.R. § 42.10
`
`Case No. IPR2016-00419
`__________________________________________________________________
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`I. RELIEF REQUESTED
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`IPR2016-00419
`PATENT NO. 8,155,342
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`Pursuant to 37 C.F.R. § 42.10 and Patent Owner’s Request for Authorization
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`to file for Pro Hac Vice admission filed concurrently herewith and dated January
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`21, 2016, Patent Owner, Blitzsafe Texas, LLC, requests that the Board admit
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`Alfred R. Fabricant pro hac vice in this proceeding.1
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`II. STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO RECOGNIZE COUNSEL PRO HAC VICE DURING THE
`PROCEEDING
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`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel
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`pro hac vice during a proceeding upon showing of good cause, subject to the
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`condition that lead counsel be a registered practitioner and to any other conditions
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`as the Board may impose. 37 C.F.R. § 42.10(c) states that, “where lead counsel is
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`a registered practitioner, a motion to appear pro hac vice may be granted upon a
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`showing that counsel is an experienced litigating attorney and has an established
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`familiarity with the subject matter at issue in the proceeding.” The facts here
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`1 Patent Owner notes that it filed a motion for pro hac vice admission of Mr.
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`Fabricant in another co-pending inter partes review proceeding, IPR2016-00118,
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`where the motion is currently pending. Patent Owner also notes that it is
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`simultaneously filing motions for pro hac vice admission of Mr. Fabricant in three
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`other related inter partes review proceedings: IPR2016-00418, -00421, and -
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`00422.
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`1
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`IPR2016-00419
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`PATENT NO. 8,155,342
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`establish good cause for the Board to recognize Alfred R. Fabricant pro hac vice
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`during this proceeding:
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`1. Lead counsel, Peter Lambrianakos, is a registered practitioner.
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`2. Counsel, Alfred R. Fabricant, is an experienced patent litigator and
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`has an established familiarity with the subject matter at issue in the proceeding.
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`Accompanying this motion is the Declaration of Alfred R. Fabricant in Support of
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`this Motion for Admission Pro Hac Vice of Alfred R. Fabricant (“Fabricant
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`Decl.”). In his declaration, Mr. Fabricant attests that he is a member in good
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`standing of the Bar of the States of New York and Arizona, and is also admitted to
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`practice in the United States District Courts for the Southern District of New York,
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`the Eastern District of New York, the District of Arizona, and the Eastern District
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`of Texas; the United States Courts of Appeal for the Federal Circuit, the Second
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`Circuit, and the Fourth Circuit; and the United States Supreme Court. Fabricant
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`Decl. ¶2.
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`3. Mr. Fabricant is an experienced litigating attorney. More
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`specifically, he has over 20 years of patent litigation experience. Fabricant Decl.
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`¶1. Mr. Fabricant has been a first-chair litigator in over 30 patent infringement
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`cases. Fabricant Decl. ¶1.
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`4. Mr. Fabricant also attests that he is familiar with the subject matter
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`and patent at issue in this proceeding. He is lead counsel for Blitzsafe Texas, LLC
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`2
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`IPR2016-00419
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`PATENT NO. 8,155,342
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`in five related matters asserting claims for infringement of the patent at issue in
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`this proceeding. Those matters are Blitzsafe Texas, LLC v. Hyundai Motor
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`Company et al., No. 15-cv-01275-JRG (E.D. Tex.); Blitzsafe Texas, LLC v. Honda
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`Motor Co., Ltd. et al., No. 15-cv-01274-JRG (E.D. Tex.); Blitzsafe Texas, LLC v.
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`Volkswagen Group of America, Inc. et al., No. 15-cv-01278-JRG (E.D. Tex.);
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`Blitzsafe Texas, LLC v. Nissan Motor Co., Ltd. et al., No. 15-cv-01276-JRG (E.D.
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`Tex.); and Blitzsafe Texas, LLC v. Toyota Motor Corporation et al., No. 15-cv-
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`01277-JRG (E.D. Tex.). Fabricant Decl. ¶8.
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`5. Mr. Fabricant attests to each of the pro hac vice declaration
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`requirements listed in the Board’s Order in Case No. IPR2013-00639 (Paper 7).
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`Fabricant Decl., ¶¶ 1–9.
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`6. Mr. Fabricant 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 forth in Part 42
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`of 37 C.F.R. Fabricant Decl., ¶ 5.
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`7. Mr. Fabricant agrees to be subject to the USPTO Rules of
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`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a) and to be subject to the USPTO Rules of
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`Professional Conduct as set forth in Changes to Representation of Others Before
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`the United States Patent and Trademark Office; Final Rule, 78 Fed. Reg. 20180
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`(Apr. 3, 2013) (effective May 3, 2013). Fabricant Decl., ¶ 6.
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`3
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`III. CONCLUSION
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`IPR2016-00419
`PATENT NO. 8,155,342
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`The requirements for admission pro hac vice being hereby established,
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`Patent Owner respectfully requests that the Board admit Alfred R. Fabricant pro
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`hac vice as back-up counsel in this proceeding.
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`Respectfully submitted,
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`/Peter Lambrianakos /
`Lead Counsel for Petitioner
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`Peter Lambrianakos (Reg. No. 58,279)
`Lead Counsel for Petitioner
`Brown Rudnick LLP
`7 Times Square
`New York, NY 10036
`Tel: 212-209-4800
`Fax: 212-209-4801
`Email: plambrianakos@brownrudnick.com
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`Dated January 21, 2016
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`4
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`IPR2016-00419
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`PATENT NO. 8,155,342
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6(e)(4) & 42.105(b)
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`A copy of BLITZSAFE TEXAS, LLC’S MOTION FOR PRO HAC VICE
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`ADMISSION OF ALFRED R. FABRICANT PURSUANT TO 37 C.F.R. § 42.10
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`has been served on Petitioner at the correspondence of the Petitioner as follows:
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`SUGHRUE MION PLLC
`c/o William Mandir
`2100 Pennsylvania Ave NW
`Suite 800
`Washington, DC 20037
`toyota@sughrue.com
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`January 21, 2016
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`By:
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` /Peter Lambrianakos/
`
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`Peter Lambrianakos (Reg. No. 58,279)
`Lead Counsel for Petitioner
`Brown Rudnick LLP
`7 Times Square
`New York, NY 10036
`Tel: 212-209-4800
`Fax: 212-209-4801
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