`U.S. Patent No. 8,155,298 B2
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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`––––––––––
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`––––––––––
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`BRIGHT HOUSE NETWORKS, LLC,
`WIDEOPENWEST FINANCE, LLC,
`KNOLOGY OF FLORIDA, INC.,
`BIRCH COMMUNICATIONS, INC.,
`Petitioners
`
`v.
`
`FOCAL IP, LLC,
`Patent Owner
`
`––––––––––
`
`Case IPR2016-01263
`Patent No. 8,155,298 B2
`
`––––––––––
`
`Before SALLY C. MEDLEY, JONI Y. CHANG, and BARBARA A. PARVIS,
`Administrative Patent Judges.
`
`
`CORRECTED MOTION FOR SARAH J. GUSKE TO APPEAR
`PRO HAC VICE ON BEHALF OF PETITIONER
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`
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`
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`Case IPR2016-01263
`U.S. Patent No. 8,155,298 B2
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`Petitioner Bright House Networks, LLC (“Bright House”) respectfully
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`requests that the Board recognize Ms. Guske as counsel pro hac vice during this
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`proceeding.
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`I.
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`BACKGROUND
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`On October 26, 2016, Petitioner Bright House filed a Motion for Pro Hac
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`Vice Admission of Sarah J. Guske. On November 14, 2016, the Board dismissed
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`the Motion without prejudice and authorized Bright House to file a motion
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`correcting the deficiencies noted in the Board’s Order. Paper 22. Accordingly,
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`Bright House’s Corrected Motion for Pro Hac Vice Admission is being filed in
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`compliance with and pursuant to the “Order Authorizing Motion for Pro Hac Vice
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`Admission” in Case No. IPR2013-00639, Paper 7 [“the Order”], and IPR2016-
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`01263, Paper 22.
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`II.
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`STATEMENT OF FACTS
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`As required by the Order, the following statement of facts shows that there is
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`good cause for the Board to recognize Ms. Guske pro hac vice.
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`Ms. Guske is an experienced litigation attorney and has been involved in
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`numerous complex litigations in state and federal courts. Ms. Guske’s biography
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`is attached hereto as Exhibit 1057.
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`1
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`Case IPR2016-01263
`U.S. Patent No. 8,155,298 B2
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`Ms. Guske has reviewed U.S. Patent No. 8,155,298 B2 and the petition,
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`already filed in this proceeding. Further, Ms. Guske is counsel of record in the
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`related co-pending litigation between the parties, Patent Asset Licensing, LLC v.
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`Bright House Networks, LLC, No. 3:15-cv-00742-TJC (M.D. Fla.) and, as such, is
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`familiar with the subject matter at issue in this proceeding.
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`Focal IP, LLC (“Focal IP”) was consulted through its counsel in
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`correspondence dated October 3, 2016. Focal IP stated that they would not oppose
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`this motion.
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`Therefore, Bright House respectfully submits that there is good cause for the
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`Board to recognize Ms. Guske as counsel pro hac vice during this proceeding.
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`III. AFFIDAVIT OR DECLARATION OF INDIVIDUAL SEEKING TO
`APPEAR
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`
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`Bright House’s Motion for Pro Hac Vice Admission is accompanied by an
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`Affidavit of Ms. Sarah Guske as required by the Order and is attached hereto as
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`Exhibit 1056.
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`November 15, 2016
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`BAKER BOTTS L.L.P.
`ATTN: Wayne O. Stacy
`2001 Ross Ave., #800
`Dallas, TX 75201
`Tel: (214) 953-6678
`Fax: (214) 661-4678
`
`
`Respectfully submitted,
`BAKER BOTTS L.L.P.
`
`/Wayne O. Stacy/
`Wayne Stacy
`Reg. No. 45,125
`Lead Counsel
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`2
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`Case IPR2016-01263
`U.S. Patent No. 8,155,298 B2
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. §§ 42.6(e) and 42.105(b), the undersigned certifies
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`that on November 15, 2016, the foregoing was served electronically via email on
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`the following:
`
`
`
`By: /Wayne Stacy/
`Wayne Stacy
`Reg. No. 45,125
`Lead Counsel
`
`3
`
`Brent N. Bumgardner
`brent@nelbum.com
`PAL-IPR@nelbum.com
`
`John Murphy
`murphy@nelbum.com
`
`NELSON BUMGARDNER, P.C.
`3131 W. 7th Street, Suite 300
`Fort Worth, Texas 76107
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