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`Paper No.
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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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`APPLE INC.,
`Petitioner,
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`v.
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`PARTHENON UNIFIED MEMORY ARCHITECTURE LLC,
`Patent Owner
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`_____________________
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`
`
`Case IPR2016-01114
`Patent No. 7,777,753
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`_____________________
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`PETITIONER’S MOTION FOR PRO HAC VICE ADMISSION
`PURSUANT TO 37 C.F.R. § 42.10(C)
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`Petitioner’s Motion for Pro Hac Vice Admission
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`IPR2016-01114 (Patent No. 7,777,753)
`Apple Inc. respectfully moves that the Board recognize Mr. Yakov
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`Zolotorev as counsel pro hac vice during this proceeding. Patent Owner does not
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`oppose this Motion.
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`1. Time for Filing
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`This Motion for Pro Hac Vice Admission is being filed no sooner than
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`twenty one (21) days after service of the Petition. See Notice of Filing Date,
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`IPR2016-01114, paper no. 3, at 1.
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`2. Statement of Facts Showing Good Cause for Counsel Pro Hac Vice
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`Petitioner has been authorized to file motions seeking admission pro hac
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`vice under 37 C.F.R. 42.10(c). Id. at 2. Petitioner’s lead and back-up counsel are
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`registered practitioners:
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`Lead Counsel: Andrew S. Ehmke, USPTO Reg. No. 50,271;
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`Backup Counsel: David W. O’Brien, USPTO Reg. No. 40,107;
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`Michael S. Parsons, USPTO Reg. No. 58,767; and
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`David L. Alberti, USPTO Reg. No. 43,465.
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`The following statement of facts shows that there is good cause for the
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`Board to recognize Mr. Zolotorev pro hac vice on behalf of Petitioner.
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`Mr. Zolotorev is an experienced litigator that has established familiarity with
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`the subject matter at issue in this proceeding from his representation of the
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`Petitioner in Parthenon Unified Memory Architecture LLC v. Apple Inc., Case No.
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`-2-
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`Petitioner’s Motion for Pro Hac Vice Admission
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`IPR2016-01114 (Patent No. 7,777,753)
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`2:15-cv-00621-JRG (E.D. Tex. filed May 1, 2015) (“the co-pending litigation”),
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`where U.S. Patent No. 7,777,753 (“the ’753 patent”) is being asserted against the
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`Petitioner. The co-pending litigation involves the same subject patent, and if
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`admitted, Mr. Zolotorev will be involved in the depositions that occur in this
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`proceeding.
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`Mr. Zolotorev has analyzed prior art references and claim charts in
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`connection with invalidity contentions and has been involved in forming claim
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`construction positions related to the claimed inventions, all of which are relevant to
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`this inter partes review proceeding. Petitioner wishes to apply Mr. Zolotorev’s
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`knowledge of the ’753 patent by employing him as counsel in this proceeding.
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`Admission of Mr. Zolotorev pro hac vice will enable Petitioner to avoid
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`unnecessary expense and duplication of work between this proceeding and the co-
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`pending litigation.
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`Petitioner’s lead and backup counsel are registered practitioners and Mr.
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`Zolotorev is an experienced litigation attorney having familiarity with the subject
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`matter at issue in this proceeding. Therefore, Petitioner respectfully submits that
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`there is good cause for the Board to recognize Mr. Zolotorev as counsel pro hac
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`vice during this proceeding.
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`-3-
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`Petitioner’s Motion for Pro Hac Vice Admission
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`IPR2016-01114 (Patent No. 7,777,753)
`3. Declarations of Individuals Seeking to Appear
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`This Motion for Pro Hac Vice Admission is supported by the Declaration of
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`Respectfully submitted,
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` /
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`
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` Andrew S. Ehmke/
`Andrew S. Ehmke
`Registration No. 50,271
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`
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`Mr. Zolotorev (Ex. 1025).
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`Dated: February 15, 2017
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`-4-
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`Petitioner’s Motion for Pro Hac Vice Admission
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`IPR2016-01114 (Patent No. 7,777,753)
`PETITIONER’S UPDATED EXHIBIT LIST
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`February 15, 2017
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`Ex. 1001 U.S. Patent No. 7,777,753
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`Ex. 1002
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`Prosecution History of U.S. Patent No. 7,777,753
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`Ex. 1003 Declaration of Robert Colwell, Ph.D., Under 37 C.F.R. §1.68
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`Ex. 1004 Curriculum Vitae of Robert Colwell, Ph.D.
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`Ex. 1005 U.S. Patent No. 5,546,547 to Bowes et al. (“Bowes”)
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`Ex. 1007
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`Ex. 1006
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`“AT&T DSP3210 Digital Signal Processor The Multimedia
`Solution” Data Sheet March 1993 (“Datasheet”)
`Published European Patent Application EP 0626653 A1 naming
`Artieri, together with English translation and affidavit attesting to the
`accuracy of the translation (“Artieri”)
`Ex. 1008 U.S. Patent No. 6,029,217 to Arimilli et al. (“Arimilli”)
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`Ex. 1010
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`Ex. 1009 R. Gove, “The MVP: A Highly-Integrated Video Compression
`Chip”, IEEE 1994 (“Gove”)
`T. Shanley et al., “PCI System Architecture”, Addison–Wesley
`Publ’g Co. (3rd ed. Feb. 1995) (“Shanley”)
`Ex. 1011 U.S. Patent No. 5,787,264 to Christiansen et al. (“Christiansen”)
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`Ex. 1012 U.S. Patent No. 5,473,380 to Tahara (“Tahara”)
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`Ex. 1013 Claim Construction Memorandum Opinion and Order, Parthenon
`Unified Memory Architecture LLC v. Samsung Elecs. Co. Ltd. et al.,
`No. 2:14-CV-00902 (E.D. Tex.)
`File History of U.S. Patent No. 5,752,073
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`Ex. 1014
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`Ex. 1015
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`“ISO/IED 11172-2:1993 Information technology – Coding of
`moving pictures and associated audio for digital storage media at up
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`-5-
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`Petitioner’s Motion for Pro Hac Vice Admission
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`IPR2016-01114 (Patent No. 7,777,753)
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`Ex. 1016
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`Ex. 1017
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`Ex. 1018
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`to about 1,5Mbits/s- Part 2: Video;” 1st ed., August 1, 1993 (“MPEG
`Standard”)
`Texas Instruments, Inc., Houston, TX, “TMS320C8x System Level
`Synopsis,” (1995) (Literature Ref. SPRU113B) (“TMS”)
`“Pentium and Pentium Pro Processors and Related Products”, ISBN
`1-55512-265-5
`Joint Claim Construction and Prehearing Statement, Parthenon
`Unified Memory Architecture LLC v. Apple Inc., case no. 2:15-cv-
`632-JRG-RSP (Feb. 16, 2016, E.D. Tex.)
`Ex. 1019 VESA Unified Memory Architecture Hardware Specifications
`Proposal, Version 1.0p
`Institution Decision, IPR2015-01501 (U.S. Patent No. 7,777,753)
`Ex. 1020
`Ex. 1021 Bader Declaration (including Appendix A & B)
`Ex. 1022
`Institution Decision, IPR2015-01502 (U.S. Patent No. 7,542,045)
`Joint Claim Construction Chart, Parthenon Unified Memory
`Ex. 1023
`Architecture LLC v. Apple Inc., case no. 2:15-cv-632-JRG-RSP
`(April 4, 2016, E.D. Tex.)
`Ex. 1024 Microprocessor Report, MPEG Choices for PCs Abound (July 31,
`1995).
`Ex. 1025 Declaration of Yakov Zolotorev in Support of Motion for Pro Hac
`Vice Admission
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`-6-
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`Petitioner’s Motion for Pro Hac Vice Admission
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`IPR2016-01114 (Patent No. 7,777,753)
`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(a), this is to certify that I
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`caused to be served a true and correct copy of the foregoing “PETITIONER’S
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`MOTION FOR PRO HAC VICE ADMISSION PURSUANT TO 37 C.F.R. §
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`42.10(C)” as detailed below:
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`Date of service February 15, 2017
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`Manner of service Electronic Mail to: manjom@azalaw.com
`aalavi@azalaw.com; sclark@azalaw.com; and
`mmcbride@azalaw.com
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`Documents served PETITIONERS’ MOTION FOR PRO HAC VICE
`ADMISSION PURSUANT TO 37 C.F.R. § 42.10(C);
`Petitioner’s Updated Exhibit List; and Exhibit 1025
`
`Masood Anjom
`Amir Alavi
`Scott Clark
`Michael McBride
`AHMAD, ZAVITSANOS, ANAIPAKOS, ALAVI &
`MENSING P.C.
`1221 McKinney, Suite 2500
`Houston, TX 77010
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`Persons served
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`/Andrew S. Ehmke/
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`Andrew S. Ehmke
`Registration No. 50,271
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`-7-
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