`______________
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________
`
`
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`Apple Inc., Samsung Electronics Co. Ltd., and Samsung Electronics America, Inc.,
`Petitioners,
`
`
`
`v.
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`Rosetta-Wireless Corporation,
`Patent Owner.
`______________
`
`
`
`Case IPR 2016-00616
`Patent 7,149,511
`______________
`
`
`
`PATENT OWNERS’ MOTION FOR PRO HAC VICE ADMISSION
`OF DANIEL A. ZAHEER 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
`
`(“Federal Regulations”), Patent Owner Rosetta-Wireless Corporation (“Patent
`
`Owner” or “Rosetta”) respectfully requests the pro hac vice admission of Daniel
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`A. Zaheer as backup counsel for Rosetta in the current proceedings. The
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`Petitioners LG Electronics U.S.A., Inc. and LG Electronics, Inc. (“Petitioners”)
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`were consulted regarding this request, and have indicated through counsel that they
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`would not oppose. A declaration made by Mr. Zaheer in support of this motion is
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`attached hereto as Exhibit 2002.
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`I. Statement of Facts
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`1. Mr. Zaheer is a litigation attorney experienced in patent cases, and is
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`admitted to practice law in California as well as multiple Federal Courts, including
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`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 Eastern District of Texas
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`e. United States Court of the Appeals for the Ninth Circuit
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`f. United States Court of the Appeals for the Federal Circuit
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`g. United States Supreme Court
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`1
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`2. Mr. Zaheer has not had any application denied for admission to practice, nor
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`has 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. Zaheer has an established familiarity with the subject matter at issue in
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`this proceeding, having represented Rosetta in District Court proceedings
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`involving the same technology (Rosetta-Wireless Corp. v. Apple Inc. et al., Lead
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`Case No. 15-cv-00799, (N.D. Ill) and Rosetta-Wireless Corp. v. LG Electronics
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`Co. and LG Electronics USA Inc., No. 15-cv-10608, (N.D. Ill)). Mr. Zaheer has
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`carefully studied the patent-in-suit, including its prosecution history, and has
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`conducted many interviews with the inventors regarding their invention, the
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`prosecution history and the patent. Mr. Zaheer is intimately familiar with the
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`positions taken by the petitioners and the other defendants in the above litigation,
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`and has provided counsel to the inventors in connection with litigation involving a
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`foreign counterpart in the United Kingdom. Mr. Zaheer is an experienced patent
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`litigator, having litigated numerous patent infringement cases, for both plaintiffs
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`and defendants, at both the district court and Federal Circuit levels. Mr. Zaheer
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`has, for example, served as trial and appellate counsel for the Australian national
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`science agency, Commonwealth Scientific and Industrial Research Organisation,
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`including in the currently pending CSIRO v. Cisco, Eastern District of Texas Case
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`No. 6-11-cv-343.
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`2
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`4. Mr. Zaheer has read and will comply with the Office Patent Trial Practice
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`Guide 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 Daniel A. Zaheer pro hac vice during the
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`proceeding.
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`
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`Dated: September 13, 2016
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`
`KOBRE & KIM
`
`
`
`
`/s/ Daniel A. Zaheer
`Daniel A. Zaheer (Pro Hac Vice Pending)
`Kobre & Kim LLP
`150 California, 19th Floor
`San Francisco, California 94111
`daniel.zaheer@kobrekim.com
` (415) 582-4751
`
`Attorney for Patent Owner Rosetta-
`Wireless Corp.
`
`
`
`
`3
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`CERTIFICATE OF SERVICE
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`
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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 DANIEL A. ZAHEER PURSUANT TO 37 C.F.R. § 42.10(c) was served via
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`email to lead and backup counsel of record for Petitioners as follows:
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`
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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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`
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`/s/ Daniel A. Zaheer
`Daniel A. Zaheer (Pro Hac Vice Pending)
`Attorney for Patent Owner Rosetta-
`Wireless Corp.
`
`
`
`Dated: September 13, 2016
`
`
`
`
`
`4
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