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Atty Docket No. FABO-037-01US
`(309101-2112)

`
`
`
`
` IPR2016-00718
`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 COMMUNICATIONS LTD.
`Patent Owner
`
`
`
`Case IPR2016-00718
`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-037-01US
`(309101-2112)

`
`
`
`
` IPR2016-00718
`U.S. Patent No. 8,874,677
`
`Petitioner WhatApp Inc. respectfully requests that the Board recognize
`
`Reuben Chen, 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. Chen pro hac vice.
`
`Mr. Chen is an experienced litigation attorney and has been involved in
`
`numerous complex litigations in state and federal courts. Mr. Chen’s biography is
`
`attached hereto as Exhibit 1124 to this Motion.
`
`Mr. Chen has reviewed U.S. Patent No. 8,874,677, and the petition already
`
`filed in this proceeding. Further, Mr. Chen 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.
`
`Therefore, Petitioner respectfully submits that there is good cause for the
`
`Board to recognize Mr. Chen as counsel pro hac vice during this proceeding.
`
`  
`
`1 
`
`

`
`Atty Docket No. FABO-037-01US
`(309101-2112)

`III.
`
`AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
`
`
`
`
` IPR2016-00718
`U.S. Patent No. 8,874,677
`
`Petitioners’ Motion for Pro Hac Vice Admission is accompanied by an
`
`Affidavit of Reuben Chen attached hereto as Exhibit 1125 as required by the
`
`Order.
`
`Dated: April 8 2016
`
`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-037-01US
`(309101-2112)
`
`
`
`
`
` IPR2016-00718
`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
`(Reuben Chen) and related documents, are being served via electronic mail on the
`8th day of April, 2016, the same day as the filing of the above-identified document
`in the United States Patent and Trademark Office/Patent Trial and Appeal Board,
`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
`
`DATED: April 8, 2016
`
`/ Heidi L. Keefe /
`Heidi L. Keefe
`Reg. No. 40,673
`
`
`
`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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