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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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`KOIOS PHARMACEUTICALS LLC,
`Petitioner,
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`v.
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`MEDAC GESELLSCHAFT FÜR KLINISCHE
`SPEZIALPRÄPARATE MBH,
`Patent Owner.
`____________________
`
`Case IPR2016-01370
` Patent No. 8,664,231
`____________________
`
`
`MOTION FOR ADMISSION PRO HAC VICE OF
`KAYVAN B. NOROOZI
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`IPR2016-01370
`MOTION FOR ADMISSION PRO HAC VICE
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`I.
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`RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(c), Petitioner Koios Pharmaceuticals
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`LLC respectfully requests that the Patent Trial and Appeal Board admit
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`Kayvan B. Noroozi pro hac vice in this proceeding.
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`II. GOVERNING LAW, RULES, AND PRECEDENT
`Section 42.10(c) provides that “where lead counsel is a registered
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`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 established familiarity with the
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`subject matter at issue in the proceeding.”
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`III. STATEMENT OF FACTS
`The facts here satisfy § 42.10(c) and demonstrate good cause for the
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`Board to recognize Mr. Noroozi pro hac vice in this proceeding.
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`Lead counsel, DeAnn Smith, and first back-up counsel, William
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`Rothwell, are registered practitioners. Counsel, Kayvan B. Noroozi, is an
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`experienced patent litigator in good standing with the California State Bar,
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`admitted to practice before the United States District Courts for the Eastern
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`District of Texas and Northern District of California, and has never been
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`suspended, disbarred, sanctioned, cited for contempt of court, or had a court
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`or administrative body deny his application for admission to practice. Ex.
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`1
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`IPR2016-01370
`MOTION FOR ADMISSION PRO HAC VICE
`1038 ¶¶ 1-5. Mr. Noroozi’s declaration includes a list of the proceedings
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`before the Office in which he has applied to appear pro hac vice in the last
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`three years. Id. at ¶ 6. Mr. Noroozi has read and will comply with the Office
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`Patent Trial Practice Guide and the Board’s Rules of Practice for Trials set
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`forth in part 42 of title 37 of the Code of Federal Regulations. Id. at ¶ 7. Mr.
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`Noroozi understands and accepts that he will be subject to the USPTO Rules
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`of Professional Conduct set forth in 37 C.F.R. §§ 11.101 et. seq. and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a). Id. at ¶ 8. Mr. Noroozi
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`is familiar with the subject matter at issue in this proceeding through his
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`review of the underlying patent, the record, and discussions with Petitioner,
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`its counsel, and its expert witness. Id. at ¶ 9.
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`IV. CONCLUSION
`For the foregoing reasons, Petitioner respectfully requests that the
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`Board admit Kayvan B. Noroozi pro hac vice in this proceeding.
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`2
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`IPR2016-01370
`MOTION FOR ADMISSION PRO HAC VICE
`Respectfully submitted,
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`/DeAnn F. Smith/
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`DeAnn F. Smith (Lead Counsel)
`Reg. No. 36,683
`FOLEY HOAG LLP
`155 Seaport West
`Boston, MA 02210
`dsmith@foleyhoag.com
`
`William P. Rothwell (Back-Up Counsel)
`Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
`william@noroozipc.com
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`Counsel for Petitioner
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`Date: August 18, 2017
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`3
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`IPR2016-01370
`MOTION FOR ADMISSION PRO HAC VICE
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`
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`CERTIFICATION OF SERVICE
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`The undersigned hereby certifies that the foregoing MOTION FOR
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`ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI was served
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`electronically via e-mail on August 18, 2017, in its entirety on the following
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`counsel of record for Patent Owner:
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`
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`James F. Haley (Lead Counsel)
`Brian Gummow (Back-up Counsel)
`Service E-mail address
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`james.haley@hglaw.com
`brian.gummow@hglaw.com
`IPR2016-01370_Medac@ropesgray.com
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`Respectfully submitted,
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`/s/ William Rothwell
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`William P. Rothwell (Back-Up Counsel)
`Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
`william@noroozipc.com
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`Counsel for Petitioner
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`
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`Date: August 18, 2017
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`4
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