`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`___________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`___________________
`
`DELL INC.; EMC CORPORATION; HEWLETT-PACKARD
`ENTERPRISE CO.; and HP ENTERPRISE SERVICES, LLC,
`
`Petitioners,
`
`v.
`
`REALTIME DATA LLC,
`
`Patent Owner.
`___________________
`
`Case IPR2017-00176
`Patent 7,161,506
`___________________
`
`PATENT OWNER REALTIME DATA LLC’S MOTION TO
`WITHDRAW STERNE KESSLER GOLDSTEIN AND FOX PLLC AS
`COUNSEL
`
`
`
`
`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent and Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`
`Submitted Electronically via the PTAB E2E System
`
`
`
`
`
`IPR2017-00176
`MOTION TO WITHDRAW COUNSEL
`
`I. RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(e), and as authorized by the Board in an e-mail
`
`dated June 13, 2017, Patent Owner Realtime Data LLC (“Realtime”) requests the
`
`Board withdraw all attorneys and agents associated with STERNE KESSLER
`
`GOLDSTEIN AND FOX P.L.L.C., who are currently only back-up counsel for Realtime.
`
`Specifically, for this inter partes review proceeding Realtime requests authorization
`
`to withdraw Jason D. Eisenberg, Donald J. Featherstone, Joseph E. Mutschelknaus,
`
`Robert Greene Sterne, and Tyler J. Dutton as counsel.
`
`
`
`Patent Owner has conferred with Petitioners’ counsel. Petitioners do not
`
`oppose this motion.
`
`II.
`
`STATEMENT OF REASONS FOR SUBSTITUTION OF COUNSEL
`
`Realtime wishes for current lead counsel William P. Rothwell (Registration
`
`No. 72,522) and current first back-up counsel Kayvan B. Noroozi (admitted pro hac
`
`vice) of NOROOZI P.C. to remain and be the only representatives for Patent Owner
`
`going forward in this proceeding.
`
`
`
`Realtime’s current lead counsel Mr. Rothwell and back-up counsel Mr.
`
`Noroozi meet the requirements of 37 C.F.R. § 42.10(c), so no substitution of counsel
`
`is necessary.
`
`
`
`- 2 -
`
`
`
`IPR2017-00176
`MOTION TO WITHDRAW COUNSEL
`It is believed that granting this Motion will not hinder the economy, the
`
`integrity of the patent system, the efficient administration of the Office, or the ability
`
`of the Office to timely complete this proceeding. See 35 U.S.C. § 316(b).
`
`A new executed Power of Attorney is being filed concurrently.
`
`Updated Mandatory Notices Under 37 C.F.R. § 42.8(b)(3) and (b)(4) will be
`
`filed upon grant of the present motion.
`
`Respectfully submitted,
`
`/s/ William Rothwell
`
`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
`
`Kayvan B. Noroozi, Admitted Pro Hac Vice
`NOROOZI PC
`1299 Ocean Ave., Suite 450
`Santa Monica, CA 90401
`
`
`Counsel for Patent Owner
`
`Date: June 20, 2017
`
`
`
`- 3 -
`
`
`
`IPR2017-00176
`MOTION TO WITHDRAW COUNSEL
`CERTIFICATION OF SERVICE
`
`The undersigned hereby certifies that the foregoing PATENT OWNER
`
`
`
`REALTIME DATA LLC’S MOTION TO WITHDRAW STERNE
`
`KESSLER GOLDSTEIN AND FOX PLLC AS COUNSEL and accompanying
`
`Power of Attorney were served electronically via e-mail on June 20, 2017, in their
`
`entirety on the following counsel of record for Petitioner:
`
`Andrew R. Sommer (Lead Counsel)
`Thomas M. Dunham (Back-up Counsel)
`Garth A. Winn (Back-up Counsel)
`Vivek V. Krishnan (Back-up Counsel)
`IPR2017-00176@winston.com
`garth.winn@klarquist.com
`
`
`
`/s/ William Rothwell
`
`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
`
`Counsel for Patent Owner
`
`
`
`- 4 -
`
`
`
`Date: June 20, 2017
`
`
`
`
`
`
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