`
`______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`______________
`
`
`
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`
`
`REALTIME DATA, LLC D/B/A IXO
`Patent Owner
`
`_____
`
`Case No. IPR2016-01365
`U.S. Patent No. 7,181,608
`______________
`
`
`
`PATENT OWNER’S MOTION FOR ADMISSION PRO HAC VICE
`OF DAVID M. SAUNDERS
`
`
`
`
`
`
`
`
`
`
`
`
`I.
`
`Case No. IPR2016-01365
`U.S. Patent No. 7,181,608
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner Realtime Data, LLC d/b/a/
`
`IXO (“Realtime”) respectfully requests that the Patent Trial and Appeal Board
`
`admit David M. Saunders pro hac vice in this proceeding, IPR2016-01365.
`
`II.
`
`STATEMENT OF FACTS DEMONSTRATING GOOD CAUSE TO
`RECOGNIZE COUNSEL PRO HAC VICE IN THIS PROCEEDING
`
`In accordance with 37 C.F.R. § 42.10(c), 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. Section 42.10(c) indicates that “where lead counsel is a
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`registered practitioner, a motion to appear pro hac vice by counsel who is not a
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`registered practitioner may be granted upon a showing that counsel is an
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`experienced litigating attorney and has an established familiarity with the subject
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`matter at issue in the proceeding.” The facts here establish good cause for the
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`Board to recognize Mr. Saunders pro hac vice in this proceeding.
`
`1.
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`Lead counsel, Richard Z. Zhang (Reg. No. 73,397) is a registered
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`practitioner.
`
`2.
`
`Counsel, David M. Saunders, is an experienced litigator and has an
`
`established familiarity with the subject matter at issue in the proceeding.
`
`Accompanying this motion as Exhibit 2001 is the August 2, 2016, Declaration of
`
`
`
`2
`
`
`
`
`David M. Saunders in Support of this Motion for Admission Pro Hac Vice
`
`Case No. IPR2016-01365
`U.S. Patent No. 7,181,608
`
`(“Saunders Decl.”). In his declaration, Mr. Saunders asserts:
`
`I am a member in good standing of the Bar of the State of
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`California and the Bar of the District of Columbia, and
`
`am admitted to practice before the United States Courts
`
`of Appeal for the Federal Circuit, the United States
`
`District Court for the Central District of California, and
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`the United States District Court for the Northern District
`
`of California.
`
`Saunders Decl. ¶ 2 (Exhibit 2001). Mr. Saunders further asserts:
`
`I am familiar with the subject matter at issue in this
`
`proceeding. I am currently counsel in the case of
`
`Realtime Data, LLC d/b/a IXO v. Apple, Inc., U.S.
`
`District Court for the Northern District of California case
`
`no. 3:16-cv-02595.
`
`Saunders Decl. ¶ 9 (Exhibit 2001). Mr. Saunders further asserts:
`
`I understand that I will be subject to the USPTO Rules of
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`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et.
`
`seq. and disciplinary
`
`jurisdiction under 37 C.F.R.
`
`§11.19(a).
`
`
`
`3
`
`
`
`
`Saunders Decl. ¶ 8 (Exhibit 2001).
`
`Case No. IPR2016-01365
`U.S. Patent No. 7,181,608
`
`III. CONCLUSION
`For the foregoing reasons, Patent Owner respectfully requests that the Board
`
`admit David M. Saunders pro hac vice in this proceeding.
`
`
`
`Respectfully Submitted,
`
`/Richard Z. Zhang/
`Richard Z. Zhang
`FISCH SIGLER LLP
`5301 Wisconsin Avenue NW
`Fourth Floor
`Washington, DC 20015
`(202) 362-3527
`Richard.Zhang.IPR@fischllp.com
`
`David M. Saunders
`FISCH SIGLER LLP
`96 North Third Street
`Suite 260
`San Jose, CA 95112
`(650) 362-8208
`David.Saunders.IPR@fischllp.com
`
`Counsel for Realtime Data, LLC
`d/b/a IXO
`
`
`Date: August 2, 2016
`
`
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`
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`
`
`4
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`
`
`Case No. IPR2016-01365
`U.S. Patent No. 7,181,608
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a copy of the foregoing Patent
`
`
`
`
`
`Owner’s Motion for Admission Pro Hac Vice of David M. Saunders was
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`served on August 2, 2016, via email directed to counsel of record for Petitioners:
`
`
`W. Karl Renner
`IPR39521-0023IP1@fr.com
`
`
`
`By: /Richard Z. Zhang/
` Richard Z. Zhang
`
`
`
`
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`
`
`5
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