Case IPR2016-00450
`U.S. Patent No. 8,462,920
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`––––––––––
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`––––––––––
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`Twilio Inc.
`Petitioner
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`v.
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`Telesign Corporation
`Patent Owner
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`––––––––––
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`Case IPR2016-00450
`Patent No. 8,462,920
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`––––––––––
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`Before SALLY C. MEDLEY, JUSTIN T. ARBES, and
`KIMBERLY McGRAW, Administrative Patent Judges.
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`MOTION FOR SARAH J. GUSKE TO APPEAR PRO HAC VICE ON
`BEHALF OF PETITIONER
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`Case IPR2016-00450
`U.S. Patent No. 8,462,920
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`Petitioner respectfully requests that the Board recognize Ms. Guske 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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`Petitioner’s Motion for Pro Hac Vice Admission is being filed in compliance
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`with and pursuant to the “Order – Authorization Motion for Pro Hac Vice
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`Admission” in Case No. IPR2013-00639 [“the Order”].
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`II.
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`STATEMENT OF FACTS
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`As required by the Order, the following statement of facts shows that there is
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`good cause for the Board to recognize Ms. Guske pro hac vice.
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`Ms. Guske is an experienced litigation attorney and has been involved in
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`numerous complex litigations in state and federal courts. Ms. Guske’s biography is
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`attached hereto as Exhibit A.
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`Ms. Guske has reviewed U.S. Patent No. 8,462,920 and the petition, already
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`filed in this proceeding. Further, Ms. Guske is counsel of record in the co-pending
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`litigation between the parties, Telesign Corp. v. Twilio Inc., No. 2:15-cv-03240-
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`PSG (C.D. Cal), and Telesign Corp. v. Twilio Inc., No. 2:16-cv-02106-PSG (C.D.
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`Cal), and as such, is familiar with the subject matter at issue in this proceeding.
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`Case IPR2016-00450
`U.S. Patent No. 8,462,920
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`Patent Owner was consulted through its counsel on October 3, 2016 and
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`Patent Owner stated that they do not oppose this motion.
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`Therefore, Petitioner respectfully submits that there is good cause for the
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`Board to recognize Ms. Guske as counsel pro hac vice during this proceeding.
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`III. AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
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`Petitioner’s Motion for Pro Hac Vice Admission is accompanied by an
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`Affidavit of Ms. Sarah Guske as required by the Order, attached hereto as Exhibit
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`Respectfully submitted,
`BAKER BOTTS L.L.P.
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`/Wayne O. Stacy/
`Wayne Stacy
`Reg. No. 45,125
`Lead Counsel
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`2
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`B.
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`October 5, 2016
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`BAKER BOTTS L.L.P.
`ATTN: Wayne O. Stacy
`2001 Ross Ave., #800
`Dallas, TX 75201
`Tel: (214) 953-6678
`Fax: (214) 661-4678
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`EXHIBIT A
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`EXHIBIT A
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` Sarah J. Guske
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`Sarah Guske is a partner in the firm's Intellectual Property group with
`twelve years of experience litigating software and electronics patent
`litigation cases. She has litigated matters in district court and before the
`PTAB involving a wide variety of technologies, including
`telecommunication protocols and systems, MPEG Multimedia data for
`broadcast, telephonic voice recognition software and graphic chipset
`design. Ms. Guske also has significant appellate experience, and has
`served as an Adjunct Professor teaching patent litigation.
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`Representative Litigation Cases:
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`Interactive Systems Worldwide, Inc. v. Mikohn Gaming Corp. et al.
`(District of Nevada) - litigation counsel to Mikohn Gaming Corp. and
`STB Holdings, Inc. in patent litigation related to real-time sports betting
`technologies,
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`Zenith Electronics v. Thomson, Philips Electronics, TTE Technology,
`Pioneer Electronics (Eastern District of Texas) - litigation counsel to
`Zenith in patent litigation over patents essential for compliance with
`ATSC Digital Television Standard.
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`Bookham, Inc. v. Unaxis Balzers AG et al. (Northern District of
`California) - litigation counsel to Bookham in patent litigation related to
`color wheel technology,
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`HyperRoll Israel, Ltd. v. Hyperion Solutions (Eastern District of
`Texas) - litigation counsel to HyperRoll Israel, Ltd. in a patent litigation
`against Hyperion Solutions, The technology in this case involves
`database-management software.
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`HyperRoll, Inc. v. Hyperion Solutions (Northern District of
`California) - litigation counsel to HyperRoll, Inc. in a declaratory
`judgment action brought by Hyperion Solutions. The technology in this
`case involves database-management software.
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`Qualcomm Incorporated v. Nokia Corporation (Eastern District of
`Texas) - litigation counsel for Qualcomm in a patent infringement action
`involving cellular telephony systems and mobile TV applications.
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`PARTNER
`101 California Street
`30th Floor, Suite 3070
`San Francisco California 94111
`United States of America
`+1.415.291.6205
`+1.415.291.6305 fax
`sarah.guske@bakerbotts.com
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`EDUCATION AND HONORS
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`J.D., University of California, Davis School
`of Law, 2004
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`B.S., Electrical Engineering, Washington
`State University, 2001
`summa cum laude
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`B.A., Physics, Whitworth University, 2001
`summa cum laude
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`Recognized as a Super Lawyer-Rising Star
`(Thomson Reuters), 2014
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`Recognized as an "Associate to Watch,"
`Chambers USA, 2012
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`BAKER BOTTS
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`International Printer Corp. v. Brother International et al. (Eastern
`District of Texas) - litigation counsel for International Printer in a patent
`infringement action against twelve manufacturers of networkable multi-
`function printer and imaging technology.
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`Ronald A. Katz Technology Licensing, L.P. v. Chevron et al. (Eastern
`District of Texas) - litigation counsel for Katz in a patent infringement
`action against nine defendants. The technology involves computer
`telephony and call-center systems.
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`Ronald A. Katz Technology Licensing, L.P. v. Consolidated Edison et
`al. (Eastern District of Texas) - litigation counsel for Katz in a patent
`infringement action against nine defendants. The technology involves
`computer telephony and call-center systems.
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`Ronald A. Katz Technology Licensing, L.P. v. Comcast et al. (Eastern
`District of Texas) - litigation counsel for Katz in a patent infringement
`action against nine defendants. The technology involves computer
`telephony and call-center systems.
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`Ronald A. Katz Technology Licensing, L.P. v. Fifth Third Bancorp et
`al. (Eastern District of Texas) - litigation counsel for Katz in a patent
`infringement action against nine defendants. The technology involves
`computer telephony and call-center systems.
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`Widevine Technologies, Inc. v. Verimatrix, Inc. (Eastern District of
`Texas) - litigation counsel for Verimatrix in a patent infringement action
`involving encryption technology.
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`Widevine Technologies, Inc. v. Verimatrix, Inc. (Western District of
`Washington) - litigation counsel for Verimatrix in a patent infringement
`action involving encryption and data stream flow control technology.
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`OPTi Inc. v. nVidia Corp. (Eastern District of Texas) - litigation counsel
`for nVidia in a patent infringement action involving chipset design and
`operation.
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`OMS Investments, Inc., et al. v. TerraCycle, Inc. (District of New
`Jersey) - litigation counsel for TerraCycle in trade dress infringement and
`unfair competition action.
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`Sarah J. Guske
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`COURT ADMISSIONS &
`AFFILIATIONS
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`State Bar of California
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`State Bar of Colorado
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`United States Court of Appeals for the
`Federal Circuit
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`United States District Court for the
`Northern, Southern and Central Districts
`of California
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`United States District Court for the
`District of Colorado
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`United States District Court for the
`Eastern District of Texas
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`BAKER BOTTS
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`EXHIBIT B
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`EXHIBIT B
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`Case IPR2016-00450
`U.S. Patent No. 8,462,920
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`AFFIDAVIT OF MS. SARAH GUSKE IN SUPPORT OF
`MOTION FOR PRO HAC VICE ADMISSION
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`I, Sarah J. Guske, do hereby declare:
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`1.
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`I am a partner in the law firm Baker Botts L.L.P. Lead counsel in this
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`inter partes review proceeding is Wayne O. Stacy, who is a partner in the law firm
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`Baker Botts L.L.P. Mr. Stacy is registered to practice before the United States
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`Patent and Trademark Office and holds Registration No. 45,125. With respect to
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`this proceeding, I will work closely with Mr. Stacy.
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`2.
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`I hold a bachelor’s degree in electrical engineering from Washington
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`State University and a bachelor’s degree in physics from Whitworth University. I
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`hold a juris doctor degree from the University of California—Davis School of
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`Law.
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`3.
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`I have over 10 years of experience as a litigating attorney representing
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`clients in matters in various United States District Courts and Courts of Appeals,
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`and before the International Trade Commission. My experience includes several
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`litigation matters in the optical and electrical circuits field. I am, therefore, an
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`experienced litigating attorney. Petitioner desires, and has a need, to be represented
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`in certain aspects of these proceedings by an experienced litigating attorney.
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`4.
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`I am familiar with U.S. Patent No. 8,462,920 and with the legal
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`subject matter, technical subject matter, and prior art discussed in Petitioner’s
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`1
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`

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`Case IPR2016-00450
`U.S. Patent No. 8,462,920
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`Request for Inter Partes Review of U.S. Patent No. 8,462,920, which forms the
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`basis for this proceeding.
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`5.
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`I am a member in good standing of the Supreme Court for the State of
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`Colorado and the Supreme Court for the State of California. I am also admitted to
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`practice before the United States District Court for the Northern District of
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`California, the United States District Court for the Eastern District of Texas,
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`United States District Court for the Central District of California, the United States
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`District Court for the Southern District of California, the United States District
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`Court for Colorado, and the United States Court of Appeals for the Federal Circuit.
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`6.
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`I have never been suspended or disbarred from practice before any
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`court or administrative body.
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`7.
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`I have never had a court or administrative body deny my application
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`for admission to practice.
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`8.
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`I have never been sanctioned or cited for contempt by any court or
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`administrative body.
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`9.
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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 the C.F.R.
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`Case IPR2016-00450
`U.S. Patent No. 8,462,920
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`10.
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`I agree to be subject to the United States Patent and Trademark Office
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`Code of Professional Responsibility set forth in 37 C.F.R. §§ 10.20 et seq. and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`11.
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`In the past three (3) years, I have applied to appear before the Office
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`and was granted pro hac vice admission in the IPR2014-01166 and IPR2014-1276
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`proceedings.
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`12.
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`I declare that all statements made herein of my own knowledge are
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`true and that all statements made on information and belief are believed to be true;
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`and further that these statements were made with the knowledge that willful, false
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`statements and the like so made are punishable by fine or imprisonment, or both,
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`under Section 1001 of Title 18 of the United States Code and that such willful false
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`statements may jeopardize the validity of U.S. Patent No. 8,462,920.
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`/Sarah. J. Guske/
`Sarah J. Guske
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`Date: October 5, 2016
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`Case IPR2016-00450
`U.S. Patent No. 8,462,920
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`CERTIFICATE OF SERVICE
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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 October 5, 2016, the foregoing was served electronically via email on the
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`following:
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`Elena McFarland
`(EMCFARLAND@shb.com)
`Tawni Wilhelm
`(TWILHELM@shb.com, TeleSignIPR@shb.com)
`Jesse Camacho
`(JCAMACHO@shb.com)
`Counsel for Patent Owner, TeleSign Inc.
`Shook, Hardy & Bacon LLP
`2555 Grand Blvd.
`Kansas City, MO 64108
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`Amy Foust
`(AFOUST@shb.com)
`Counsel for Patent Owner, TeleSign Inc.
`Shook, Hardy & Bacon LLP
`201 S. Biscayne Blvd., Suite 3200
`Miami, FL 33131
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`By: /Wayne O. Stacy/
`Wayne Stacy
`Reg. No. 45,125
`Lead Counsel
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`4