UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`INTEL CORPORATION, GLOBALFOUNDRIES U.S., INC.,
`AND MICRON TECHNOLOGY, INC.,
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`Petitioners,
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`v.
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`DANIEL L. FLAMM,
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`Patent Owner.
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`Case IPR2017-00281
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`Patent RE40,264 E
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`PETITIONERS' MOTION FOR PRO HAC VICE ADMISSION
`OF CHAD S. CAMPBELL UNDER 37 C.F.R. § 42.10(c)
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`INTEL CORPORATION, GLOBALFOUNDRIES U.S., INC.,
`AND MICRON TECHNOLOGY, INC.,
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`Petitioners,
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`v.
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`DANIEL L. FLAMM,
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`Patent Owner.
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`Case IPR2017-00281
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`Patent RE40,264 E
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`PETITIONERS' MOTION FOR PRO HAC VICE ADMISSION
`OF CHAD S. CAMPBELL UNDER 37 C.F.R. § 42.10(c)
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`Petitioners' Motion for Pro Hac Vice Admission of Chad S. Campbell
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`Petitioners Intel Corporation, GLOBALFOUNDRIES U.S., INC.,
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`and Micron Technology, Inc. (collectively “Petitioners”) respectfully request that
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`the Board admit Chad S. Campbell as backup counsel pro hac vice in this
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`proceeding. Mr. Campbell is an experienced litigation attorney and has substantial
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`knowledge in the substantive issues of the invalidity of the challenged claims of
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`the Patent in this proceeding. Therefore, Mr. Campbell meets the requirements of
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`“an experienced litigating attorney and has an established familiarity with the
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`subject matter at issue in the proceeding” under 37 C.F.R. §42.10(c).
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`1. Time For Filing
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`This Motion for Pro Hac Vice Admission has been authorized by the Notice
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`of Filing Date Accorded to Petition and Time for Filing Patent Owner Preliminary
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`Response that was mailed on December 14, 2016 (Paper 3). This Motion is filed
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`no sooner than twenty one (21) days after service of the petition.
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`2.
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`Statement of Facts
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`In this proceeding, lead counsel for Petitioner is Jonathan McFarland, a
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`registered practitioner. The following statement of facts shows that there is good
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`cause for the Board to admit Mr. Campbell pro hac vice.
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`Mr. Campbell is a patent litigation attorney with more than 23 years of
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`experience representing clients in cases involving semiconductor technology,
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`1
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`Petitioners' Motion for Pro Hac Vice Admission of Chad S. Campbell
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`computer design and software. (Affidavit of Chad S. Campbell (“Campbell
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`Affidavit”), ¶ 8 in attached Exhibit 1023.)
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`Mr. Campbell regularly litigates patent cases in various forums including
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`the United States Court of Appeals for the Federal Circuit and various federal
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`district courts. (Id.) He has experience representing clients in many phases of
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`litigation including discovery, Markman hearings, jury trials, and appeals. (Id.)
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`Mr. Campbell’s biography is attached to the Campbell Affidavit (Exhibit 1023) as
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`Appendix A.
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`Mr. Campbell has an established familiarity with the subject matter at issue
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`in this proceeding, having represented Petitioner in a court proceeding against
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`Patent Owner involving the same technology (Daniel L. Flamm v. Intel
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`Corporation, 16-cv-1579 (N.D. Cal.)).
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`Mr. Campbell is familiar with the technologies and issued claims in the
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`6,017,221, RE40,264 and 5,711,849 Patents. Mr. Campbell is also familiar with
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`the prior art references cited in PTAB Case Nos IPR2017-00279 - 282, IPR2017-
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`00391- 392 and IPR2017-00406 and the associated invalidity grounds before the
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`PTAB.
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`2
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`Petitioners' Motion for Pro Hac Vice Admission of Chad S. Campbell
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`3. Affidavit or Declaration of Individual Seeking to Appear
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`This Motion for Pro Hac Vice Admission is accompanied by an Affidavit of
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`Mr. Campbell (attached Exhibit 1023), which attests to the requirements for pro
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`hac vice admission set forth in IPR2013-00639, Paper 7, dated Oct. 15, 2013.
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`4. Conclusion
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`Accordingly, Petitioners submit that there is good cause under 37 C.F.R.
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`§ 42.10(c) for the Board to admit Chad S. Campbell as counsel pro hac vice and to
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`authorize Mr. Campbell to represent Petitioners as back-up counsel in this
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`Respectfully submitted,
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` /Jonathan McFarland/
`Lead Counsel
`Jonathan McFarland, Reg. No. 61,109
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`Back-up Counsel
`Chad Campbell, Pro Hac Vice
`Tyler Bowen, Reg. No. 60,461
`Daniel Keese, Reg. No. 69,315
`Jeremy Jason Lang, Reg. No. 73,604
`Jared Bobrow, Pro Hac Vice
`David M. Tennant, Reg. No. 48,362
`Nathan Zhang, Reg. No. 71,401
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`Attorneys for Petitioners
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`3
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`proceeding.
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`Dated: January 20, 2017
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`PERKINS COIE LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
`206-359-8000
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`WEIL, GOTSHAL & MANGES LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`650-802-3237
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`WHITE & CASE LLP
`701 Thirteenth Street, NW
`Washington, DC 20005-3807
`202-626-3600
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`Petitioners' Motion for Pro Hac Vice Admission of Chad S. Campbell
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`CERTIFICATE OF SERVICE
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`The undersigned hereby certifies that a true copy of the foregoing
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`PETITIONERS' MOTION FOR PRO HAC VICE ADMISSION UNDER 37
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`C.F.R. § 42.10(c) and Exhibit 1023 was served in its entirety this 20th day of
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`January 2017 by FedEx® mail delivery service on Patent Owner at the
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`correspondence address for the ’264 Patent shown in USPTO PAIR:
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`Daniel L. Flamm
`476 Green View Drive
`Walnut Creek CA 94596
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`The above referenced documents were additionally served by FedEx® mail
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`delivery service to the following address known as likely to effect service:
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`George C. Summerfield
`Rolf O. Stadheim
`Robert M. Spalding
`STANDHEIM & GREAR, LTD.
`400 N. Michigan Avenue, Suite 2200
`Chicago, IL 60611
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`1
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`Petitioners' Motion for Pro Hac Vice Admission of Chad S. Campbell
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`Respectfully submitted,
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` /Jonathan McFarland/
`Lead Counsel
`Jonathan McFarland, Reg. No. 61,109
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`Back-up Counsel
`Chad Campbell, Pro Hac Vice
`Tyler Bowen, Reg. No. 60,461
`Daniel Keese, Reg. No. 69,315
`Jeremy Jason Lang, Reg. No. 73,604
`Jared Bobrow, Pro Hac Vice
`David M. Tennant, Reg. No. 48,362
`Nathan Zhang, Reg. No. 71,401
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`Attorneys for Petitioners
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`2
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`Dated: January 20, 2017
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`PERKINS COIE LLP
`1201 Third Avenue, Suite 4900
`Seattle, WA 98101
`206-359-8000
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`WEIL, GOTSHAL & MANGES LLP
`201 Redwood Shores Parkway
`Redwood Shores, CA 94065
`650-802-3237
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`WHITE & CASE LLP
`701 Thirteenth Street, NW
`Washington, DC 20005-3807
`202-626-3600
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