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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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`SONY CORPORATION, SONY MOBILE COMMUNICATIONS (USA) INC.,
`SONY MOBILE COMMUNICATIONS AB & SONY MOBILE
`COMMUNICATIONS INC.
`Petitioners
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`v.
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`CREATIVE TECHNOLOGY LIMITED
`Patent Owner
`_____________
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`Case No. IPR2016-01407
`Patent No. 6,928,433
`_____________
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`UNOPPOSED MOTION FOR PRO HAC VICE ADMISSION OF
`JOSHUA J. MILLER
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`I.
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`STATEMENT OF PRECISE RELIEF REQUESTED
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`Pursuant to 37 C.F.R. § 42.10(c) and Paper No. 3, Sony Corporation, Sony
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`Mobile Communications (USA) Inc., Sony Mobile Communications AB & Sony
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`Mobile Communications Inc., (“Petitioners”) respectfully request that the Patent
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`Trial and Appeal Board admit Joshua J. Miller pro hac vice in this proceeding,
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`IPR2016-01407. Creative Technology Limited does not oppose this motion.
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`II.
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`STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO RECOGNIZE COUNSEL PRO HAC VICE DURING
`THE PROCEEDING
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`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel
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`pro hac vice during a proceeding upon a showing of good cause, subject to the
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`condition that lead counsel be a registered practitioner and to any other conditions
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`that the Board may impose. Section 42.10(c) indicates that “where lead counsel is
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`a 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. Miller pro hac vice in this proceeding.
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`First, as set forth in Mr. Miller’s declaration (Ex. 1032) at paragraphs H
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`through J, Mr. Miller has familiarity with the subject matter at issue in these
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`proceedings. He has worked on preparing and reviewing the materials submitted
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`in this proceeding.
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`Second, Mr. Miller has extensive patent litigation experience and is expected
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`to use his experience to support Lead Counsel during the proceedings, including
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`during the Oral Hearing. Good cause exists to have Petitioners appoint as counsel
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`Mr. Miller, as a litigator, to assist Lead Counsel.
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`Furthermore, as set forth in his declaration, Mr. Miller attests to all of the
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`remaining matters set forth in Paper No. 7 from Unified Patents v. Parallel Iron,
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`Case IPR2013-00639 (PTAB Oct. 15, 2013).
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`III. CONCLUSION
`For the foregoing reasons, Petitioners respectfully request that the Board
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`admit Joshua J. Miller pro hac vice in this proceeding.
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`Dated: August 7, 2017
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`By:
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`Respectfully submitted,
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`/s/ Michael N. Rader
`Michael N. Rader, Reg. No. 52,146
`Randy J. Pritzker, Reg. No. 35,986
`Andrew J. Tibbetts, Reg. No. 65,139
`WOLF GREENFIELD & SACKS, P.C.
`600 Atlantic Ave.
`Boston, MA 02210-2206
`Tel: 617-646-8000 / Fax: 617-646-8646
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`CERTIFICATE OF SERVICE UNDER 37 C.F.R. § 42.6 (e)(4)
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`I certify that on August 7, 2017, I will cause a copy of the foregoing
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`document, including any exhibits or appendices referred to therein, to be served via
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`electronic mail, as previously consented to by Patent Owner, upon the following:
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`Date: August 7, 2017
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`Jonathan D. Baker
`Russell Swerdon
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`JBaker@farneydaniels.com
`russ_swerdon@creativelabs.com
`CreativeZen@farneydaniels.com
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`/MacAulay S. Rush/
`Patent Paralegal
`WOLF GREENFIELD & SACKS, P.C.
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