`(309101-2111)
`
`
`
`
`
` IPR2016-00717
`U.S. Patent No. 8,874,677
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`
`WHATSAPP INC.
`Petitioner
`
`v.
`
`TRIPLAY INC.
`Patent Owner
`
`
`
`Case IPR2016-00717
`U.S. Patent No. 8,874,677
`
`
`
`PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION
`UNDER 37 C.F.R. § 41.10(c)
`
`
`
`
`
`Atty Docket No. FABO-037-00US
`(309101-2111)
`
`
`
`
`
` IPR2016-00717
`U.S. Patent No. 8,874,677
`
`Petitioner WhatApp Inc. respectfully requests that the Board recognize Yuan
`
`Liang, Esq., as counsel pro hac vice during this proceeding.
`
`I.
`
`BACKGROUND
`
`Petitioner’s Motion for Pro Hac Vice Admission is being filed in compliance
`
`with and pursuant to the “Order—Authorizing Motion for Pro Hac Vice
`
`Admission” in Case No. IPR2013-00639 (MPT) [“the Order”].
`
`II.
`
`STATEMENT OF FACTS
`
`As required by the Order, the following statement of facts shows that there is
`
`good cause for the Board to recognize Mr. Liang pro hac vice.
`
`Mr. Liang is an experienced litigation attorney and has been involved in
`
`various complex litigations in federal courts. Mr. Liang’s biography is attached
`
`hereto as Exhibit 1026 to this Motion.
`
`Mr. Liang has studied and reviewed U.S. Patent No. 8,874,677, its
`
`prosecution history, the prior art to the ‘677 patent, and the petition filed in this
`
`proceeding. Mr. Liang was also involved in the drafting and review of the IPR
`
`petition herein. Further, Mr. Liang is familiar with the pending litigation between
`
`the parties pending before the U.S. District Court for Delaware entitled Triplay,
`
`Inc. et al. v. WhatsApp Inc., Case No. 1:13-cv-01703-LPS; and, as such, is familiar
`
`with the subject matter at issue in this proceeding. Based on his professional
`
`experience and his particular experience with the ‘677 patent, Mr. Liang is familiar
`
`
`
`1
`
`
`
`Atty Docket No. FABO-037-00US
`(309101-2111)
`
`with the subject matter at issue in this proceeding.
`
`
`
`
` IPR2016-00717
`U.S. Patent No. 8,874,677
`
`Therefore, Petitioner respectfully submits that there is good cause for the
`
`Board to recognize Mr. Liang as counsel pro hac vice during this proceeding.
`
`III. AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
`
`Petitioner’s Motion for Pro Hac Vice Admission is accompanied by a
`
`Declaration of Yuan Liang attached hereto as Exhibit 1027 as required by the
`
`Order.
`
`Dated: February 6, 2017
`
`COOLEY LLP
`ATTN: Patent Group
`1299 Pennsylvania Ave., NW, Suite 700
`Washington, DC 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
`
`
`
`
`
`
`By:
`
`
`
`
`Respectfully submitted,
`
`
`/Heidi L. Keefe/
`Heidi L. Keefe
`Reg. No. 40,673
`Counsel for Petitioner
`WhatsApp Inc.
`
`
`
`2
`
`
`
`Atty Docket No. FABO-037-00US
`(309101-2111)
`
`
`
`
`
` IPR2016-00717
`U.S. Patent No. 8,874,677
`
`CERTIFICATE OF SERVICE
`
`
`
`I hereby certify, pursuant to 37 C.F.R. Section 42.6, that a complete copy of
`the attached PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION
`(Yuan Liang) and related documents, are being served via electronic mail on the
`6th day of February, 2017, upon counsel of record for the Patent Owner as follows:
`
`Barry Schindler
`SchindlerB@gtlaw.com
`Greenberg Traurig LLP
`njdocket@gtlaw.com
`
`Jeremy J. Monaldo
`Fish & Richardson PC
`monaldo@fr.com
`
`/ Heidi L. Keefe /
`Heidi L. Keefe
`Reg. No. 40,673
`
`
`
`
`
`DATED: February 6, 2017
`
`COOLEY LLP
`Attn: Patent Docketing
`1299 Pennsylvania Ave. NW, Suite 700
`Washington, D.C. 20004
`Tel: (650) 843-5001
`Fax: (650) 849-7400
`
`
`
`
`
`1
`
`
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