`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`REACTIVE SURFACES LTD., LLP
`
`Petitioner
`
`v.
`
`TOYOTA MOTOR CORPORATION
`
`Patent Owner
`
`
`
`Caase: IPR2016-01914
`
`Patent No. 8,394,618 B2
`
`_________________________
`
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE OF
`RICO REYES
`
`
`David O. Simmons, Reg. No. 43,124
`IVC Patent Agency
`
`
`
`7637 Parkview Circle
`
`
`
`Austin, Texas 78731
`
`
`
`
`
`
`Dated: November 8, 2017
`
`Jonathan D. Hurt, Reg. No. 44,790
`McDaniel & Associates, PC
`300 West Avenue, #1316
`Austin, Texas 78701
`
`
`
`
`
`
`
`
`
`1
`
`
`
`IPR2016-01914
`
`
`
`Pursuant to 37 C.F.R § 42.10(c) and the Board’s authorization provided in
`
`Paper No. 3, Notice of Filing Date Accorded to Petition and Time for Filing Patent
`
`Owner Preliminary Response, Petitioner requests that the board grant this Motion to
`
`Admit Rico Reyes pro hac vice in this proceeding. Patent Owner has indicated that
`
`it does not object to this Motion.
`
`
`
`The Board may recognize counsel pro hac vice during a proceeding on a
`
`showing of good cause. “[W]here lead counsel is a registered practitioner, a motion
`
`to appear pro hac vice may be granted upon a showing that counsel is an experienced
`
`litigation attorney and has an established familiarity with the subject matter at the
`
`issue in the proceeding.” 37 C.F.R. § 42.10(c).
`
`
`
`Here, both lead and back-up counsel, David O. Simmons and Jonathan D.
`
`Hurt, are registered practitioners. Mr. Reyes has over sixteen years of litigation
`
`experience with a focus on general and commercial litigation since 2010. Moreover,
`
`Mr. Reyes has represented petitioner since December of 2014 on this and other
`
`matters involving intellectual property. During this time, he has established
`
`familiarity with both petitioner’s technology and petitioner’s intellectual property,
`
`including patents, patent applications, and the patent in dispute in this Inter Partes
`
`Review proceeding as well as the reasons for its invalidity. Accompanying this
`
`motion is the Declaration of Rico Reyes, where Mr. Reyes attests to his experience
`
`
`
`2
`
`
`
`IPR2016-01914
`
`and familiarity. See generally Reyes Decl. (Ex. 1052). Specifically, Mr. Reyes
`
`attests that:
`
`• He has been a practicing attorney for over sixteen years. Since 2010, his
`
`practice has focused on general, business and commercial litigation, and has
`
`included intellectual property litigation.
`
`• He is a member in good standing of the State Bar of Texas;
`
`• He is a participating member of the team that is preparing the petitioners’ IPR
`
`petition in this case and several other IPR petitions which challenge patents
`
`owned by the same patent owner that cover the same or similar technology
`
`and same or similar claimed subject matter as Patent No. 8,394,618 B2
`
` Id. ¶¶ 1-3, 10.
`
`
`
`
`
`Accordingly, these facts establish good cause to recognize Mr. Reyes in this
`
`proceeding. Thus, Petitioner requests that the Board admit Mr. Reyes pro hac vice
`
`in this proceeding.
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/David O. Simmons, Reg. No. 43,124
`David O. Simmons
`Counsel for Petitioner
`Reactive Surfaces Ltd., LLP
`
`3
`
`
`
`IPR2016-01914
`
`CERTIFICATE OF SERVICE
`
`
`
`
`I hereby certify that a true and true correct copy of the foregoing
`
`PETITIONER’S MOTION FOR ADMISSION PRO HAC VICE OF RICO REYES
`
`was served on November 8, 2017 by email on the following counsel of record for
`
`Patent Owner:
`
`Joshua A. Lorentz (joshua.lorentz@dinsmore.com)
`
`Richard H. Schabowsky (richard.schabowsky@dinsmore.com)
`
`John D. Luken (john.luken@dinsmore.com)
`
`Oleg Khariton (oleg.khariton@dinsmore.com)
`
`
`
`
`
`Dated: November 8, 2017
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`/s/David O. Simmons
`David O. Simmons
`Reg. No. 43,124
`
`Counsel for Petitioner
`Reactive Surfaces Ltd., LLP
`
`4
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
