`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
`
`RUBICON COMMUNICATIONS, LP
`Petitioner,
`
`v.
`
`LEGO A/S
`Patent Owner.
`____________
`
`Case IPR2016-01187
`Patent 8,894,066
`
`PATENT OWNER’S MOTION FOR PRO HAC VICE
`ADMISSION OF ELIZABETH A. ALQUIST
`UNDER 37 C.F.R. § 42.10
`
`
`
`U.S. Patent No. 8,894,066
`Motion for Pro Hac Vice Admission
`
`Precise Relief Requested
`
`The Patent Owner LEGO A/S (“LEGO”) respectfully requests under 37
`
`C.F.R. § 42.10(c) that the Board recognize Elizabeth A. Alquist as counsel pro hac
`
`vice in this proceeding. This motion is authorized by the Notice of Incomplete
`
`Petition entered on June 20, 2016.
`
`Statement of Facts
`
`The Board may recognize counsel pro hac vice upon a showing of good
`
`cause, subject to the condition that lead counsel be a registered practitioner and to
`
`any other conditions as the Board may impose. 37 C.F.R. § 42.10(c) provides an
`
`example of “good cause,” where “counsel is an experienced litigation attorney and
`
`has an established familiarity with the subject matter at issue in the proceeding.”
`
`For this proceeding, Lead Counsel, Brian R. Pollack, is a registered
`
`practitioner, having USPTO Registration No. 47,001. There is a good cause to
`
`grant this Motion, as Ms. Alquist is an experienced litigation attorney and has an
`
`established familiarity with the subject matter at issue in the proceeding. She is a
`
`litigation attorney with over12 years of patent litigation experience. She is a
`
`member in good standing of the Bar of Connecticut. She has never been
`
`suspended, disbarred, sanctioned, denied admission to practice, or cited for
`
`contempt by any court or administrative body. She is familiar with the subject
`
`.
`
`-2-
`
`
`
`U.S. Patent No. 8,894,066
`Motion for Pro Hac Vice Admission
`
`matter at issue and she has represented the Patent Owner in several patent and
`
`copyright litigations. Above facts and other conditions for admissibility identified
`
`by the Board are listed in the accompanying Declaration of Elizabeth A. Alquist,
`
`Ex. 2001.
`
`Conclusion
`
`For the foregoing reasons, Patent Owner respectfully submits that there is
`
`good cause for the Board to recognize Elizabeth A. Alquist as counsel pro hac vice
`
`in this proceeding.
`
`Dated: July 5, 2016
`
`.
`
`-3-
`
`Respectfully submitted,
`
`/ Brian R. Pollack /
`
`Brian R. Pollack
`Registration No. 47,001
`bpollack@daypitney.com
`Day Pitney LLP
`One Canterbury Green
`201 Broad Street
`Stamford, CT 06901
`Tel: (203) 977-7447
`Fax: (203) 826-8256
`
`Howard Grossman
`Registration No. 48,673
`hgrossman@daypitney.com
`
`
`
`U.S. Patent No. 8,894,066
`Motion for Pro Hac Vice Admission
`
`Day Pitney LLP
`7 Times Square
`New York, NY 10036
`Tel: (212) 297-5826
`Fax: (212) 916-2940
`
`Counsel for Patent Owner
`
`.
`
`-4-
`
`
`
`U.S. Patent No. 8,894,066
`Motion for Pro Hac Vice Admission
`
`Patent Owner’s Exhibit List
`
`Exhibit No.
`
`2001
`
`Exhibit Description
`Declaration of Elizabeth A. Alquist
`
`.
`
`-5-
`
`
`
`U.S. Patent No. 8,894,066
`Motion for Pro Hac Vice Admission
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that completed and
`
`entire copies of this Motion and Declaration of Elizabeth A. Alquist were served
`
`on the following counsel of record via UPS Overnight on July 5, 2016.
`
`Eric B. Meyertons
`1120 S. Capital of Texas Hwy.
`Building 2, Suite 300
`Austin, Texas 78746
`
`Chris D. Thompson
`1120 S. Capital of Texas Hwy.
`Building 2, Suite 300
`Austin, Texas 78746
`
`By:/ Brian R. Pollack /
` Brian R. Pollack
` Day Pitney LLP
` One Canterbury Green
` Stamford, CT 06901
`
`.
`
`-6-
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