`
`______________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________________
`
`RUBICON COMMUNICATIONS, LP
`
`Petitioner,
`
`
`
`v.
`
`
`
`LEGO A/S
`
`Patent Owner.
`
`________________________
`
`Case IPR2016-01187
`
`Patent 8,894,066
`
`
`
`PETITIONER’S MOTION FOR PRO HAC VICE
`ADMISSION OF RYAN T. BEARD
`UNDER 37 C.F.R. § 42.10
`
`
`
`
`
`Precise Relief Requested
`
`
`
`
`
`Petitioner Rubicon Communications, LP (“Rubicon”) respectfully requests
`
`under 37 C.F.R. § 42.10(c) that the Board recognize Ryan T. Beard as counsel pro
`
`hac vice in this proceeding.
`
`
`
`Statement of Facts
`
`
`
`
`
`§ 42.10(c) states:
`
`The Board may recognize counsel pro hac vice during a proceeding
`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. For example, where the lead counsel is a registered
`practitioner, a motion to appear pro hac vice by counsel who is not a
`registered practitioner may be granted upon showing that counsel is an
`experienced litigating attorney and has an established familiarity with
`the subject matter at issue in the proceeding.
`
`For Petitioner, Lead Counsel, Eric B. Meyertons, is a registered practitioner,
`
`having USPTO Registration No. 34876. There is good cause to grant this motion
`
`because Mr. Beard is an experienced litigating attorney and has an established
`
`familiarity with the subject matter at issue in the proceeding. Mr. Beard is a
`
`shareholder at the law firm of Meyertons, Hood, Kivlin, Kowert & Goetzel. He has
`
`been practicing law since 1999. Mr. Beard has litigated cases, including patent
`
`infringement cases, for the past 13 years. He has been counsel at trial and argued
`
`numerous Markman hearings, summary judgment proceedings, and other patent-
`
`
`
`related hearings and pleadings concerning, inter alia, patent validity and
`
`infringement issues. Mr. Beard is an attorney in good standing of the Bar of Texas.
`
`Mr. Beard has never been suspended, disbarred, sanctioned, denied admission to
`
`practice, or cited for contempt by any court or administrative body.
`
`
`
`Additionally, Mr. Beard is very familiar with the subject matter at issue in this
`
`case. He is lead counsel for Rubicon in the case between Rubicon and Lego A/S in
`
`the District of Connecticut, which involves the patent at issue in this Petition. As
`
`lead counsel in this related action, he is heavily involved with all aspects of the
`
`litigation, including factual investigation and forming non-infringement and
`
`invalidity positions against the challenged patent. He has also studied and reviewed
`
`the prior art asserted in the Petition, and is very familiar with the ‘066 Patent, its
`
`claims, and the technology at issue in the patent.
`
`
`
`All facts asserted herein are supported by the Declaration of Ryan T. Beard,
`
`filed concurrently with this motion.
`
`
`
`Conclusion
`
`
`
`For the reasons stated herein, Petitioner respectfully requests that there is good
`
`cause for the board to recognize Ryan T. Beard as counsel pro hac vice in this
`
`proceeding.
`
`
`
`
`
`Date: July 8, 2016
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/Eric B. Meyertons/
`Eric B. Meyertons
`Registration No. 34876
`emeyertons@intprop.com
`MEYERTONS, HOOD,
`KIVLIN, KOWERT &
`GOETZEL
`1120 S. Capital of Texas Hwy.
`Building 2, Suite 300
`Austin, Texas 78746
`(512) 853-8888
`
`
`
`Chris D. Thompson
`Registration No. 43188
`emeyertons@intprop.com
`MEYERTONS, HOOD,
`KIVLIN, KOWERT &
`GOETZEL
`1120 S. Capital of Texas Hwy.
`Building 2, Suite 300
`Austin, Texas 78746
`(512) 853-8877
`
`
`
`
`
`
`
`
`Petitioner’s Exhibit List
`
`Exhibit No.
`1022
`
`Exhibit Description
`Declaration of Ryan T. Beard
`
`
`
`
`
`
`
`Certificate of Service
`
`
`
`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that completed and
`
`entire copies of the Motion and Declaration of Ryan T. Beard were served on the
`
`following counsel of record via Federal Express on July 8, 2016.
`
`/Eric B. Meyertons/
`Eric B. Meyertons
`Registration No. 34876
`emeyertons@intprop.com
`MEYERTONS, HOOD,
`KIVLIN, KOWERT &
`GOETZEL
`1120 S. Capital of Texas Hwy.
`Building 2, Suite 300
`Austin, Texas 78746
`(512) 853-8888
`
`Brian R. Pollack
`One Canterbury Green
`201 Broad Street
`Stamford, CT 06901
`
`Howard Grossman
`7 Times Square
`New York, NY 10036
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