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`Filed on behalf of Cellular Communications Equipment LLC
`By: Terry A. Saad (tsaad@bcpc-law.com)
`
`Jeffrey R. Bragalone (jbragalone@bcpc-law.com)
`Daniel F. Olejko (dolejko@bcpc-law.com)
`Nicholas C. Kliewer (nkliewer@bcpc-law.com)
`Bragalone Conroy PC
`2200 Ross Ave.
`Suite 4500 – West
`Dallas, TX 75201
`Tel: 214.785.6670
`Fax: 214.786.6680
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`HTC CORPORATION and HTC AMERICA, INC.,
`Petitioners,
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`v.
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`CELLULAR COMMUNICATIONS EQUIPMENT LLC,
`Patent Owner.
`
`Case IPR2016-01501
`U.S. Patent No. 8,457,676
`
`
`
`
`PRO HAC VICE MOTION TO ADMIT ATTORNEY
`JONATHAN H. RASTEGAR PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`Mail Stop PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, Virginia 22313-1450
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`
`
`
`IPR2016-01501
`Patent 8,457,676
`Patent Owner Cellular Communications Equipment LLC (“CCE”) hereby
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`files this motion pursuant to 37 C.F.R. § 42.10(c) for Jonathan H. Rastegar to appear
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`pro hac vice on its behalf before the Patent Trial and Appeal Board in IPR2016-
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`001501. This Motion follows the guidelines set forth in IPR2013-00639, Paper 7,
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`entered October 15, 2013.
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`I. Factual Background
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`CCE has already designated a registered practitioner, Terry A. Saad (Reg.
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`No.62,492) as lead counsel, and CCE intends to designate Mr. Rastegar as one of its
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`back-up counsel in the event that this motion is granted. The following statement of
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`facts shows that there is good cause for the Board to recognize Mr. Rastegar pro hac
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`vice during this proceeding.
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`Mr. Rastegar is a patent litigator with over eight years’ experience, including
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`significant experience in the area of patent validity and invalidity. In the many patent
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`litigations in which he has been counsel, he has worked extensively on issues relating
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`to 35 U.S.C. §§ 101, 102, 103, and 112. Mr. Rastegar’s work includes reviewing and
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`analyzing numerous prosecution histories, reviewing and analyzing prior art
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`references, developing arguments for contentions, briefing for motions to dismiss,
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`summary judgment motions, appeals, working closely with experts on their reports,
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`conducting discovery, taking depositions, and preparing arguments for trial.
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`
`
`IPR2016-01501
`Patent 8,457,676
`Mr. Rastegar has also spent significant time learning the procedure of inter partes
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`review proceedings.
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`Mr. Rastegar currently represents CCE in a number of pending matters before
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`the U.S. District Court for the Eastern District of Texas, which include litigations
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`involving U.S. Patent No. 8,457,676. See, e.g., Cellular Communications Equipment
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`LLC v. AT&T Inc., et al., C.A. No. 2:15-cv-576 (E.D. Tex. 2015) (asserting U.S.
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`Patent No. 8,457,676); Cellular Communications Equipment LLC v. HTC Corp., et
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`al., C.A. No. 2:17-cv-078 (E.D. Tex. 2017) (asserting U.S. Patent No. 8,457,676);
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`Cellular Communications Equipment LLC v. ZTE Corp., et al., C.A. No. 2:17-cv-
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`079 (E.D. Tex. 2017) (asserting U.S. Patent No. 8,457,676). As counsel for CCE,
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`Mr. Rastegar has become very familiar with patents that cover technology that is
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`similar to the technology at issue in this proceeding (e.g., cellular telephone
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`systems). Further, Mr. Rastegar assisted in the development of arguments in support
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`of the Patent Owner’s Response and Preliminary Response in this matter, including
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`spending time preparing and reviewing the filings.
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`Given Mr. Rastegar’s familiarity with the underlying technology, the patent
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`at issue, and the prior art, CCE asks that the Board grant this Motion to afford CCE
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`the benefit of having an additional attorney authorized on this matter.
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`
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`IPR2016-01501
`Patent 8,457,676
`II. Attestation of Facts by Mr. Rastegar
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`Mr. Rastegar has submitted a declaration herewith attesting to the following
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`facts:
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` Mr. Rastegar is an attorney at the law firm Bragalone Conroy PC,
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`located at Chase Tower, 2200 Ross Avenue, Suite 4500W, Dallas,
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`Texas 75201.
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` Mr. Rastegar is a member in good standing of the Texas State Bar.
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` Mr. Rastegar has never been subject to any suspensions or disbarments
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`from practice before any court or administrative body.
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` None of Mr. Rastegar’s applications for admission to practice before
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`any court or administrative body has ever been denied.
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` Mr. Rastegar has never been sanctioned nor had contempt citations
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`imposed by any court or administrative body.
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` Mr. Rastegar has read and will comply with the Office Patent Trial
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`Practice Guide and the Board’s Rules of Practice for Trials set forth in
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`37 C.F.R. pt. 42.
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` Mr. Rastegar will be subject to the USPTO Rules of Professional
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`Conduct set forth in 37 C.F.R. § 11.101, et seq., and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a).
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`
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`IPR2016-01501
`Patent 8,457,676
` This is Mr. Rastegar’s first application to appear pro hac vice in a
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`proceeding before the Board.
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` Mr. Rastegar has familiarity with the subject matter at issue in this
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`proceeding as set forth in Section I above.
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`
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`Dated: October 30, 2017
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`Respectfully submitted,
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`________________________
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`Terry A. Saad (Reg. No. 62,492)
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`Attorney for Patent Owner
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`Bragalone Conroy PC
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`2200 Ross Ave.
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`Suite 4500 – West
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`Dallas, TX 75201
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`IPR2016-01501
`Patent 8,457,676
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`CERTIFICATE OF SERVICE
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`
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`The undersigned hereby certifies that this document has been served via
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`electronic mail on October 30, 2017, to Petitioners at the following email addresses:
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`steve.moore@pillsburylaw.com,
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`brian.nash@pillsburylaw.com,
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`rene.mai@pillsburylaw.com, and docket_ip@pillsburylaw.com pursuant
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`to
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`Petitioners’ consent in its Petition at page 3.
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`________________________
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`Terry A. Saad (Reg. No. 62,492)
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`
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`Attorney for Patent Owner
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`Bragalone Conroy PC
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`2200 Ross Ave.
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`Suite 4500 – West
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`
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`Dallas, TX 75201
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