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`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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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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`Juniper Networks, Inc.,
`Petitioners
`v.
`ChriMar Systems, Inc.,
`Patent Owner
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`______________________
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`Case No. IPR2016-01391
`U.S. Patent No. 8,942,107
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`JUNIPER NETWORKS., INC.'S UNOPPOSED MOTION FOR
`ADMISSION PRO HAC VICE OF JONATHAN KAGAN
`UNDER 37 C.F.R. § 42.10
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`Case IPR2016-1391
`Patent No. 8,942,107
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`RELIEF REQUESTED
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`I.
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`Pursuant to 37 C.F.R. § 42.10(c) and the Board's "Notice of Filing Date
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`Accorded to the Petition and Time for Filing Patent Owner's Preliminary
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`Response" entered July 12, 2016, Paper 4, granting authorization to file motions
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`for pro hac vice admission under 37 C.F.R. § 42.10(c), Petitioner Juniper
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`Networks, Inc., requests that the Board admit Jonathan Kagan pro hac vice in this
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`proceeding.
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`II.
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`STATEMENT OF FACTS
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`Pursuant to 37 C.F.R. § 42.10(c), the Board
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`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.
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`37 C.F.R. § 42.10(c). The facts, supported by the Declaration of Jonathan Kagan
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`in Support of Motion for Admission Pro Hac Vice ("Kagan Decl.", Ex. 1019),
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`establish good cause to admit Jonathan Kagan pro hac vice in this proceeding.
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`10131832
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`Case IPR2016-01391
`Patent No. 8,942,107
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`1.
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`Lead counsel Nima Hefazi is a registered practitioner and is
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`experienced in inter partes proceedings before the USPTO.
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`2.
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`Backup counsel Michael R. Fleming is a registered practitioner and
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`experienced in inter partes proceedings before the USPTO.
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`3.
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`Jonathan Kagan is an experienced litigating attorney. Mr. Kagan has
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`extensive experience in patent law and has been litigating patent cases for over
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`twenty (20) years. Kagan Decl. ¶ 11. Mr. Kagan is a member in good standing of
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`the California State Bar, with no suspensions or disbarments from practice, nor any
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`application for admission to practice denied, nor any sanctions or contempt
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`citations. Kagan Decl. ¶¶ 1-6. Mr. Kagan is also admitted to practice before the
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`United States District Courts for the Central District, Eastern District and Northern
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`District of California; Supreme Court of California; U.S. Court of Appeals, 5th
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`Circuit; U.S. Court of Appeals, 9th Circuit; and U.S. Court of Appeals for the
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`Federal Circuit. Kagan Decl. ¶ 2.
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`4. Mr. Kagan has familiarity with the subject matter at issue in this
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`proceeding. Kagan Decl. ¶ 12.
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`5. Mr. Kagan has read and will comply with the Office Patent Trial
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`Practice Guide and the Board's Rules for Practice for Trials set forth in Title 42 of
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`the C.F.R., and he agrees to be subject to the USPTO Code of Professional
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`Case IPR2016-01391
`Patent No. 8,942,107
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`Responsibility set forth in 37 C.F.R. §§ 11.101 et seq., and to disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a). Kagan Decl. ¶¶ 7-8.
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`6. Mr. Kagan has appeared (and was granted) pro hac vice before the
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`United States Patent and Trademark Office on behalf of Juniper Networks, Inc. in
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`IPR2014-00425 and IPR2014-00431. Mr. Kagan has also appeared pro hac vice in
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`IPR2016-00806 and IPR2016-01243. Kagan Decl. ¶ 10
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`7. Mr. Kagan is seeking pro hac vice admission in co-pending matters
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`IPR2016-01389, IPR2017-01397, and IPR2016-01399. Kagan Decl. ¶ 9.
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`III. ANALYSIS
`The facts contained in the Statement of Facts above, and contained in the
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`Kagan Declaration, establish that there is good cause to admit Jonathan Kagan pro
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`hac vice in this proceeding under 37 C.F.R. § 42.10. Lead and backup counsel are
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`registered practitioners, Mr. Kagan is an experienced litigating attorney, and Mr.
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`Kagan has an established familiarity with the subject matter at issue in the
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`proceeding.
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`IV. NO OPPOSITION TO THIS MOTION
`Petitioner has confirmed with Patent Owner that they do not oppose the
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`present motion.
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`Case IPR2016-01391
`Patent No. 8,942,107
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`V. CONCLUSION
`For the foregoing reasons, Juniper Networks, Inc. respectfully requests that
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`the Board admit Jonathan Kagan pro hac vice in this proceeding.
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`Dated: February 23, 2017
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`Respectfully submitted,
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`By:
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` /s/ Nima Hefazi /
` Nima Hefazi
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`Nima Hefazi (Reg. No. 63,658)
`Michael R. Fleming (Reg. No. 67,633)
`IRELL & MANELLA LLP
`1800 Avenue of the Stars, Suite 900
`Los Angeles, CA 90067-4276
`Telephone: (310) 277-1010
`Fax: (310) 203-7199
`Email: Juniper-ChrimarIPR@irell.com
`Attorneys for Petitioner,
`Juniper Networks, Inc.
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`Case IPR2016-01391
`Patent No. 8,942,107
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6, the undersigned certifies that on
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`February 23, 2017, a copy of the foregoing document and supporting Declaration
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`(Ex. 1019) were served, by electronic mail, as agreed to by the parties, upon the
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`Richard W. Hoffman
`Reising Ethington PC
`755 West Big Beaver Road Suite 1850
`Troy, Michigan 48084
` Direct: 248.786.0163
`Fax: 248.689.4071
`Hoffmann@reising.com
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`Frank A. Angileri
`Thomas A. Lewry
`Marc Lorelli
`Christopher C. Smith
` Brooks Kushman P.C.
`1000 Town Center Twenty-Second Floor
` Southfield, MI 48075-1238
`Phone: (248) 358-4400
`Fax: (248) 358-3351
`CHRMC0109IPR1@brookskushman.com
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` /s/ Susan M. Langworthy/
` Susan M. Langworthy
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`following:
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