`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`
`APPLE INC.,
`Petitioner,
`
`v.
`
`REALTIME DATA, LLC D/B/A IXO,
`Patent Owner.
`____________________
`
`Case IPR2016-01737
`Patent No. 8,880,862
`____________________
`
`
`
`MOTION FOR ADMISSION PRO HAC VICE OF
`KAYVAN B. NOROOZI
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`Submitted Electronically via the PTAB E2E System
`
`
`
`IPR2016-01737
`MOTION FOR ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI
`
`I.
`
`RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner Realtime Data LLC
`
`(“Realtime”) respectfully requests that the Patent Trial and Appeal Board
`
`admit Kayvan B. Noroozi pro hac vice in this proceeding, IPR2016-01737.
`
`II. GOVERNING LAW, RULES, AND PRECEDENT
`Section 42.10(c) provides that “where 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 a showing that counsel is an
`
`experienced litigating attorney and has established familiarity with the
`
`subject matter at issue in the proceeding.”
`
`III. STATEMENT OF FACTS
`The facts here satisfy § 42.10(c) and demonstrate good cause for the
`
`
`
`Board to recognize Mr. Noroozi pro hac vice in this proceeding.
`
`
`
`Lead counsel, William Rothwell, is a registered practitioner. Counsel,
`
`Kayvan B. Noroozi, is an experienced patent litigator in good standing with
`
`the California State Bar, admitted to practice before the United States
`
`District Courts for the Eastern District of Texas and Northern District of
`
`California, and has never been suspended, disbarred, sanctioned, cited for
`
`contempt of court, or had a court or administrative body deny his application
`
`for admission to practice. Ex. 2002 ¶¶ 1-5. Mr. Noroozi’s declaration
`
`
`
`1
`
`
`
`IPR2016-01737
`MOTION FOR ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI
`
`includes a list of the proceedings before the Office in which he has applied
`
`to appear pro hac vice in the last three years. Id. at ¶ 6. Mr. Noroozi has read
`
`and will comply with the Office Patent Trial Practice Guide and the Board’s
`
`Rules of Practice for Trials set forth in part 42 of title 37 of the Code of
`
`Federal Regulations. Id. at ¶ 7. Mr. Noroozi understands and accepts that he
`
`will be subject to the USPTO Rules of Professional Conduct set forth in 37
`
`C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. §
`
`11.19(a). Id. at ¶ 8. Mr. Noroozi is familiar with the subject matter at issue in
`
`this proceeding through his review of the underlying patent, the record, and
`
`discussions with Patent Owner, its counsel, and its expert witness. Id. at ¶ 9.
`
`IV. CONCLUSION
`For the foregoing reasons, Patent Owner respectfully requests that the
`
`
`
`Board admit Kayvan B. Noroozi pro hac vice in this proceeding.
`
`Respectfully submitted,
`
`/William P. Rothwell/
`
`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
`
`Counsel for Patent Owner
`
`
`2
`
`Date: May 30, 2017
`
`
`
`
`
`
`IPR2016-01737
`MOTION FOR ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI
`
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that the foregoing MOTION FOR
`
`ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI was served
`
`electronically via e-mail on May 30, 2017, in its entirety on the following
`
`counsel of record for Petitioner:
`
`
`
`W. Karl Renner – IPR39521-0025IP1@fr.com
`
`Respectfully submitted,
`
`/William P. Rothwell/
`
`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
`
`Counsel for Patent Owner
`
`
`
`Date: May 30, 2017
`
`
`
`3
`
`