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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`LG Electronics U.S.A., Inc. and LG Electronics, Inc.,
`Petitioners,
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`v.
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`Rosetta-Wireless Corporation,
`Patent Owner.
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`Case IPR 2016-01516
`Patent 7,149,511
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`PATENT OWNERS’ MOTION FOR PRO HAC VICE ADMISSION
`OF MICHAEL NG PURSUANT TO 37 C.F.R. § 42.10(c)
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`PRELIMINARY STATEMENT
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`Pursuant to 37 C.F.R. § 42.10(c) of the Code of Federal Regulations
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`(“Federal Regulations”), Patent Owner Rosetta-Wireless Corporation (“Patent
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`Owner” or “Rosetta”) respectfully requests the pro hac vice admission of Michael
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`Ng as backup counsel for Rosetta in the current proceedings. The Petitioners LG
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`Electronics U.S.A., Inc. and LG Electronics, Inc. (“Petitioners”) were consulted
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`regarding this request, and have indicated through counsel that they would not
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`oppose. A declaration made by Mr. Ng in support of this motion is attached hereto
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`as Exhibit 2001.
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`I. Statement of Facts
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`1. Mr. Ng is a litigation attorney experienced in patent cases, and is admitted to
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`practice law in California, New York, and Mississippi as well as multiple Federal
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`Courts, including the following:
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`a. United States District Court for the Northern District of California
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`b. United States District Court for the Eastern District of California
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`c. United States District Court for the Central District of California
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`d. United States District Court for the Southern District of California
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`e. United States District Court for the Eastern District of Texas
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`f. United States District Court for the Northern District of Mississippi
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`g. United States District Court for the Southern District of Mississippi
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`h. United States District Court for the Southern District of New York
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`i. United States Court of the Appeals for the Second Circuit
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`j. United States Court of the Appeals for the Fifth Circuit
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`k. United States Court of the Appeals for the Ninth Circuit
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`l. United States Court of the Appeals for the Federal Circuit
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`m. United States Supreme Court
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`2. Mr. Ng has not had any application denied for admission to practice, nor has
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`he been sanctioned, cited for contempt, suspended or disbarred from practice,
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`before any court or administrative body.
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`3. Mr. Ng has an established familiarity with the subject matter at issue in this
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`proceeding, having represented Rosetta in District Court proceedings involving the
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`same technology (Rosetta-Wireless Corp. v. Apple Inc. et al., Lead Case No. 15-
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`cv-00799, (N.D. Ill) and Rosetta-Wireless Corp. v. LG Electronics Co. and LG
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`Electronics USA Inc., No. 15-cv-10608, (N.D. Ill)). Mr. Ng has carefully studied
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`the patent-in-suit, including its prosecution history, and has conducted many
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`interviews with the inventors regarding their invention, the prosecution history and
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`the patent. Mr. Ng is intimately familiar with the positions taken by the petitioners
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`and the other defendants in the above litigation, and has provided counsel to the
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`inventors in connection with litigation involving a foreign counterpart in the
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`United Kingdom. Mr. Ng is an experienced patent litigator, having litigated
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`dozens of patent infringement cases, for both plaintiffs and defendants, at both the
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`district court and Federal Circuit levels. Mr. Ng has, for example, served as lead
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`trial and appellate counsel for the Australian national science agency,
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`Commonwealth Scientific and Industrial Research Organisation, including in the
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`currently pending CSIRO v. Cisco, Eastern District of Texas Case No. 6-11-cv-
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`343.
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`4. Mr. Ng has read and will comply with the Office Patent Trial Practice Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of the C.F.R.
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`II. Conclusion
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`For the reasons stated above, Patent Owner respectfully submits that there is
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`good cause for the Board to recognize Michael Ng pro hac vice during the
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`proceeding.
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`Dated: September 13, 2016
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`KOBRE & KIM
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`/s/ Michael Ng
`Michael Ng (Pro Hac Vice Pending)
`Kobre & Kim LLP
`150 California, 19th Floor
`San Francisco, California 94111
`michael.ng@kobrekim.com
`(415) 582-4803
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`Attorney for Patent Owner Rosetta-
`Wireless Corp.
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that pursuant to 37 C.F.R. § 42.6(e), a copy of the
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`foregoing PATENT OWNERS’ MOTION FOR PRO HAC VICE ADMISSION
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`OF MICHAEL NG PURSUANT TO 37 C.F.R. § 42.10(c) was served via email to
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`lead and backup counsel of record for Petitioners as follows:
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`Brian A. Tollefson of Rothwell, Figg, Ernst & Manbeck, P.C.
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`btollefson@rfem.com
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`KOBRE & KIM
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`/s/ Michael Ng
`Michael Ng (Pro Hac Vice Pending)
`Attorney for Patent Owner Rosetta-
`Wireless Corp.
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`Dated: September 13, 2016
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