Paper No. __
`Filed: May 6, 2016
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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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`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
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`v.
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`UUSI, LLC d/b/a NARTRON
`Patent Owner
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`____________________
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`Case IPR2016-00908
`Patent No. 5,796,183
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`PATENT OWNER’S MOTION FOR
`PRO HAC VICE ADMISION OF TERESA M. SUMMERS
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`Filed: May 6, 2016
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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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`SAMSUNG ELECTRONICS CO., LTD.
`Petitioner
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`v.
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`UUSI, LLC d/b/a NARTRON
`Patent Owner
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`____________________
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`Case IPR2016-00908
`Patent No. 5,796,183
`____________________
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`PATENT OWNER’S MOTION FOR
`PRO HAC VICE ADMISION OF TERESA M. SUMMERS
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`Case IPR2016-00908
`Patent No. 5,796,183
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`Patent Owner UUSI, LLC d/b/a/ Nartron. (“UUSI” or “Patent Owner”)
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`respectfully requests that the Board recognize and admit Teresa M. Summers as
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`counsel pro hac vice to represent UUSI during the above-captioned proceeding.
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`The bases and support for UUSI’s requests are as follows.
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` 1. Timing of UUSI’s Request
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`UUSI’s motion is being filed no sooner than twenty-one (21) days after the
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`service of the petition.
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` 2. Good Cause Basis for UUSI’s Request
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`The Board may recognize counsel pro hac vice during a proceeding upon a
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`showing of good cause, subject to the condition that lead counsel is a registered
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`practitioner and a declaration of the party seeking admission is included with the
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`Request. 37 C.F.R. § 42.10(c). Good cause has been shown where, for example,
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`the attorney for which pro hac vice admission is sought is an experienced patent
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`litigator and has a familiarity with the subject matter at issue in the proceeding, and
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`the admission of the party’s counsel will facilitate the party’s ability to effectively
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`participate in the proceeding. UUSI respectfully submits that all of these
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`conditions have been met here.
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`Case IPR2016-00908
`Patent No. 5,796,183
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`UUSI’s lead counsel, Jay P. Kesan, is a registered practitioner. See Exhibit
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`2000, Declaration of Teresa M. Summers in Support of Motion for Admission Pro
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`Hac Vice (“Summers Decl.”), at ¶ 15.
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`As demonstrated by her declaration, Ms. Summers is an experienced
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`litigator who has litigated patent infringement cases for various parties in federal
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`district courts throughout the United States, the U.S. Court of Appeals for the
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`Federal Circuit, and the International Trade Commission. Id. at ¶¶3-7. Ms.
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`Summers clerked at the Court of Appeals for the Federal Circuit and represents
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`clients in appeals before that Court. Id. at ¶¶4, 6. Her legal career spans over
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`thirteen (13) years. See Id. at ¶¶3, 7. Ms. Summers has extensive experience in
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`litigating patent infringement cases, and has served as lead counsel in such cases.
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`Id. at ¶¶3-7.
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`Ms. Summers is familiar with the subject matter of this proceeding. She
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`represents UUSI in an intellectual property dispute pending at the Court of Federal
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`Claims, UUSI, LLC, et. al. v. The United States, et. al., Case No. 12-216 C, Ct.
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`Fed. Cl. (“UUSI v. US”). Id. at ¶13. While the specific patents at issue in UUSI v.
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`US do not include U.S. Pat. No. 5,796,183 (the “’183 Patent”), in her role as
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`UUSI’s counsel and during the course of litigating on behalf of UUSI, Ms.
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`Summers has become familiar with UUSI’s technological innovations and patent
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`portfolio, including the ’183 Patent. Id. Ms. Summers has analyzed and studied
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`Case IPR2016-00908
`Patent No. 5,796,183
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`the ’183 Patent. Id. Further, Ms. Summers has litigated patent infringement issues
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`involving touch sensors on behalf of other clients. For example, Ms. Summers was
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`part a team that represented Immersion Corporation, a developer of touch feedback
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`technology, in patent litigation involving touchscreen products. Id. Ms. Summers
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`has reviewed and is familiar with the ’183 Patent, its prosecution history, the prior
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`art and other arguments concerning the validity of the patent made by petitioner.
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`Id.
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`UUSI submits that Ms. Summers’s participation will assist it and its lead
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`counsel in effectively participating in this proceeding, and will facilitate timely
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`completion of the trial proceeding.
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`Ms. Summers has never been suspended, disbarred, sanctioned or cited for
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`contempt by any court or administrative body, and has never had an application for
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`admission to practice before a court or agency denied. Id. at ¶¶8-9. Ms. Summers
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`is a member in good standing of the Bar of Virginia. Id. at ¶2. Ms. Summers has
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`further agreed, as indicated in his declaration, to read and to be subject to the
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`Office Patent Trial Practice Guide, the Board’s Rules of Practice for Trials set
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`forth in part 42 of 37 C.F.R, and the USPTO’s Rules of Professional Conduct set
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`forth in 37 C.F.R. §§ 11.101 et. seq., and submit to disciplinary jurisdiction under
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`37 C.F.R. § 11.19(a). Id. at ¶¶10-11.
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`Case IPR2016-00908
`Patent No. 5,796,183
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`3. Conclusion
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`For the foregoing reasons, UUSI respectfully requests that the PTAB
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`recognize Teresa M. Summers as its counsel, pro hac vice, in this proceeding.
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`Dated: May 6, 2016
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`Respectfully submitted,
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`/s/ Jay P. Kesan
`By:
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`Jay P. Kesan
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`Reg. No. 37,488
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`Counsel for Patent Owner
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`5
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`Case IPR2016-00908
`Patent No. 5,796,183
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on the date
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`indicated below, a complete and entire copy of this submission was provided by
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`email to Petitioner’s counsel via email, as agreed to by Petitioner’s Service
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`Information in the April 15, 2016 Petition submission, by serving the email address
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`of record as follows:
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`naveenmodi@paulhastings.com;
`josephpalys@paulhastings.com;
`chetanbansal@paulhastings.com.
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`Dated: May 6, 2016
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`Respectfully submitted,
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`/s/ Jay P. Kesan
`By:
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`Jay P. Kesan
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`Reg. No. 37,488
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`Counsel for Patent Owner
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`6
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