`______________________
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`______________________
`
`APPLE INC. and FITBIT, INC.,
`Petitioner
`
`v.
`
`VALENCELL, INC.
`Patent Owner
`______________________
`
`Case No.: IPR2017-00319
`Patent No. 8,923,941
`______________________
`
`PETITIONER’S UNOPPOSED MOTION FOR ADMISSION
`PRO HAC VICE OF SAM STAKE UNDER 37 C.F.R. § 42.10(c)
`
`
`
`Case No.: IPR2017-00319
`Patent No. 8,923,941
`Petitioner Fitbit, Inc. respectfully requests the Board recognize Sam Stake as
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`counsel pro hac vice during this proceeding.
`
`I.
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`Background
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` This Motion for Admission is being filed in compliance with and pursuant to
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`the “Order-Authorizing Motion for Pro Hac Vice Admission” in Case No.
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`IPR2013-00639 (MPT) (the “Order”) and the Board’s authorization provided in the
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`Notice of Filing Date Accorded to Petition etc. (Paper No. 3). Patent Owner does
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`not oppose this request.
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`II.
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`Statement of Facts Showing Good Cause
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`Petitioner has been authorized to file motions seeking admission pro hac
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`vice under 37 C.F.R. § 42.10(c). Paper No. 3. Petitioner’s lead counsel is a
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`registered practitioner:
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`Lead Counsel: James M. Glass, Reg. No. 46,729
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`As demonstrated below and in the accompanying declaration (Ex. 1073),
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`there is good cause for the Board to recognize Mr. Stake pro hac vice. Mr. Stake is
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`an experienced litigation attorney and has been involved in numerous litigations
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`involving patent infringement in district court and the Federal Circuit. Mr. Stake’s
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`biography is attached hereto as Exhibit 1074.
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`Furthermore, Mr. Stake has established familiarity with the subject matter at
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`issue in this proceeding, including U.S. Patent No. 8,923,941 and the petition filed
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`
`
`Case No.: IPR2017-00319
`Patent No. 8,923,941
`in this proceeding, all exhibits accompanying the petition, and all other documents
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`filed in this action.
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`Therefore, Petitioner respectfully submits that there is good cause for the
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`Board to recognize Mr. Stake as counsel pro hac vice during this proceeding.
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`III. Declaration of Individual Seeking to Appear
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`This Motion for Admission Pro Hac Vice is accompanied by a Declaration
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`of Sam Stake attached hereto as Exhibit 1073, as required by the Order.
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`Date: September 3, 2020
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`Respectfully submitted,
`
`/s/ James M. Glass
`James M. Glass (Reg. No. 46,729)
`Attorney Lead Counsel
`QUINN EMANUEL URQUHART,
` & SULLIVAN, LLP
`
`
`
`Case No.: IPR2017-00319
`Patent No. 8,923,941
`
`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of the foregoing
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`PETITIONER’S UNOPPOSED MOTION FOR ADMISSION
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`PRO HAC VICE OF SAM STAKE UNDER 37 C.F.R. § 42.10(c) was served on
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`September 3, 2020 via email directed to counsel of record for the Patent Owner at
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`the following:
`
`Justin B. Kimble
`Nicholas C. Kliewer
`BRAGALONE CONROY PC
`2200 Ross Avenue, Suite 4500 W
`Dallas, Texas 75201
`Email: JKimble-IPR@bcpc-law.com
`Email: nkliewer@bcpc-law.com
`
`Dated: September 3, 2020
`
`/James M. Glass/
`James M. Glass (Reg. No. 46,729)
`Attorney Lead Counsel
`
`Quinn Emanuel Urquhart &
`Sullivan, LLP
`
`Attorney for Petitioner – Fitbit, Inc.
`
`