`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`APPLE INC.,
`Petitioner
`
`V.
`
`IMMERSION CORPORATION,
`
`Patent Owner
`
`CASE: IPR2016-01381
`
`Patent No. 8,773,356
`
`MOTION FOR PRO HAC VICE ADMISSION
`
`UNDER 37 C.F.R. § 42.10
`
`
`
`Petitioner Apple Inc. (“Petitioner” or “Apple”) respectfiilly requests that the
`
`Board recognize Mr. Robert Williams as counsel pro hac vice during this
`
`proceeding.
`
`1.
`
`Time For Filing
`
`This Motion for Pro Hac Vice Admission is being filed no sooner than
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`twenty one (21) days after service of the petition as required by the Notice of
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`Filing Date Accorded to Petition and Time for Filing Patent Owner Preliminary
`
`Response entered July 12, 2016. Paper No. 3 at 2 (citing “Order - Authorizing
`
`Motion for Pro Hac Vice Admission” in Case IPR2013—00639, Paper No. 7).
`
`2.
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`Statement of Facts
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`As required by the Notice authorizing this Motion for Pro Hac Vice
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`Admission (Paper No. 3), the following statement of facts shows that there is good
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`cause for the Board to recognize Mr. Williams pro hac vice.
`
`Mr. Williams is an experienced litigation attorney, and has been involved in
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`numerous litigations involving patent infringement in District Courts across the
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`country. He has experience in jury and bench trials, Markman hearings, and oral
`
`arguments in patent infringement litigation matters.
`
`US. Patent No. 8,773,356 (the “’356 patent”) is assigned to Immersion
`
`Corporation (“Immersion” or “Patent Owner”). The ’356 patent is related to six
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`other patents currently asserted by Immersion against Apple in the co—pending
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`
`
`investigation In the Matter of Certain Mobile And Portable Devices Incorporating
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`Haptics (Including Smartphones And Laptops) And Components Thereof. United
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`States International Trade Commission Investigation No. 337-TA—1004/990.
`
`These patents include US. Patent Nos. 8,659,571 (the “’571 patent”), 8,619,051
`
`(the “’051 patent”), 8,581,710 (the “’710 patent”), 8,749,507 (“the ’507 patent”),
`
`7,808,488 (“the ’488 patent”), and 7,336,260 (“the “260 patent”).
`
`Mr. Williams is counsel for Apple in the co—pending litigation and, as such,
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`has an established familiarity with the subject matter at issue in this proceeding. In
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`the co-pending litigation, Mr. Williams has reviewed prior art references and
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`invalidity contention claim charts, and was involved in forming claim construction
`
`positions, some of which are relied upon in the petition requesting inter partes
`
`review of US. Patent No. 8,581,710. Petitioner has expended significant financial
`
`resources in the co-pending litigation with Mr. Williams as counsel, and Petitioner
`
`wishes to continue using Mr. Williams as counsel in this proceeding.
`
`Further, counsel for Patent Owner does not oppoLSe Mr. Williams appearing
`
`pro hac vice during this proceeding. Therefore, Petitioner respectfully submits that
`
`there is good cause for the Board to recognize Mr. Williams as counsel pro hac
`
`vice during this proceeding.
`
`
`
`3.
`
`Affidavit or Declaration of Individual Seeking to Appear
`
`This Motion for Pro Hac Vice Admission is accompanied by an Affidavit of
`
`Mr. Robert Williams as required by the Notice of Filing Date Accorded to Petition
`
`and Time for Filing Patent Owner Preliminary Response entered July 12, 2016.
`
`Respectfully Submitted,
`
`r/s/ James M Heintz
`
`James M. Heintz
`
`Registration Number 41,828
`DLA Piper LLP (US)
`11911 Freedom Drive, Suite 300
`
`Reston, VA 20190
`703—773-4148
`
`Attorneyfor Petitioner
`
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that a true copy of the foregoing instrument
`
`
`
`was served on Patent Owner Immersion Corporation by emailing a copy to counsel
`
`at the email addresses listed below:
`
`Michael R. Fleming
`
`Irell & Manella LLP
`
`Babak Redjaian
`
`Irell & Manella LLP
`
`1800 Avenue of the Stars, Suite 900
`
`1800 Avenue of the Stars, Suite 900
`
`Los Angeles, CA 90067-4276
`
`Los Angeles, CA 90067-4276
`
`310-277-1010 (telephone)
`
`949-760-5260 (telephone)
`
`310-203-7199 (fax)
`
`mfleming@irell.com
`
`949-760-5200 (fax)
`
`bredjaian@irell.com
`
`ImmersionIPR@irell.com
`
`ImmersionIPR@irell.com
`
`
`
`
`
`
`
`
`
`By:
`
` /James M. Heintz/
`James M. Heintz
`
`Reg. No. 41,828
`
` Counsel for Petitioner
`
`
`
`
`
`
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`
`
`Date: May 10, 2017
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