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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
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`v.
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`IMAGE PROCESSING TECHNOLOGIES, LLC,
`Patent Owner
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`Case IPR2017-00336
`Patent 6,959,293 B2
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`MOTION FOR PRO HAC VICE ADMISSION
`OF MARK A. CHAPMAN
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`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner respectfully requests the pro
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`hac vice admission of Mark A. Chapman as backup counsel for Patent Owner in
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`the current proceedings. A declaration made by Mark A. Chapman in support of
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`this motion is attached hereto as Exhibit A.
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`1. Mr. Chapman is a partner at the law firm of Andrews Kurth Kenyon
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`LLP.
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`2. Mr. Chapman is a litigation attorney experienced in patent cases and is a
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`member in good standing of the New York Bar. He has not had any
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`application denied for admission to practice, nor has he been sanctioned,
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`cited for contempt, suspended or disbarred from practice, before any
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`court or administrative body.
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`3. Mr. Chapman has an established familiarity with the subject matter at
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`issue in this proceeding, including U.S. Pat. No. 6,959,293 (“the ’293
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`patent”), and the petition for inter partes review submitted by
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`Petitioners as shown in his accompanying declaration.
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`4.
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`In his declaration, Mr. Chapman also attests to each of the listed items
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`required by the Order – Authorizing Motion for Pro Hac Vice
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`Admission – 37 C.F.R. § 42.10 in IPR2013-00639.
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`5. Motions for Pro Hac Vice Admission of Mr. Chapman are being
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`concurrently filed in the following related Inter Partes Review
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`proceedings:
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`i. IPR2017-00347
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`ii. IPR2017-00353
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`iii. IPR2017-00355
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`iv. IPR2017-00357
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`For the reasons stated above, Patent Owner respectfully submits that there is
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`good cause for the Board to recognize Mark A. Chapman pro hac vice during the
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`/s/ Chris J. Coulson
`Chris J. Coulson (Reg. No. 61,771)
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, New York 1004-1007
`Tel: (212) 425-7200
`Fax: (212) 425-5288
`chriscoulson@andrewskurthkenyon.com
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`Michael Zachary (pro hac vice)
`MichaelZachary@AndrewsKurthKenyon.com
`Mark Chapman (pro hac vice)
`MarkChapman@AndrewsKurthKenyon.com
`Rose Cordero Prey (pro hac vice)
`RosePrey@AndrewsKurthKenyon.com
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`
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`proceeding.
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`Date: March 20, 2017
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on March 20,
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`2017, the foregoing Motion for Pro Hac Vice Admission of Mark A. Chapman is
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`being served via electronic mail upon the following counsel of record for
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`Petitioner:
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`John Kappos (Reg. No. 37,861) jkappos@omm.com
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`Nick Whilt (Reg. No. 72,081) nwhilt@omm.com
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`Brian M. Cook (Reg. No. 59,356) bcook@omm.com
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`IPTSAMSUNGOMM@omm.com
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`/s/ Chris J. Coulson
`Chris J. Coulson
`Registration No. 61,771
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004
`(212) 425-7200
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`Attorney for Patent Owner
`Image Processing Technologies, LLC
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`EXHIBIT A
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`EXHIBIT A
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`I, Mark A. Chapman, declare as follows:
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`1. This declaration is given in support of Image Processing Technologies,
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`LLC’s Motion for Pro Hac Vice Admission of Mark A. Chapman under 37
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`C.F.R. § 42.10(c).
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`2.
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`If admitted pro hac vice in this matter, I will serve as counsel with Chris
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`Coulson, also of the law firm Andrews Kurth Kenyon LLP. Mr. Coulson is
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`lead counsel and is a registered practitioner.
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`3.
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`I am a partner at the law firm Andrews Kurth Kenyon LLP, where my
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`practice focuses on patent-related matters, and in particular, patent
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`litigation in a variety of technical fields.
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`4.
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`I have over 15 years’ experience in the field of patent law. My practice
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`focuses on patent litigation in district courts around the country, appeals at
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`the Federal Circuit, and Patent Office proceedings, such as reexaminations
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`and inter partes review proceedings. For example, in the past several years,
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`I have been involved in, inter alia, the following Patent Office inter partes
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`reexaminations and inter partes review proceedings:
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`a. Inter Partes Review Case IPR2015-01838 (admitted pro hac vice)
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`b. Inter Partes Review Case IPR2016-00291 (admitted pro hac vice)
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`c. Inter Partes Review Case IPR2016-00292 (admitted pro hac vice)
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`d. Inter Partes Review Case IPR2016-00293 (admitted pro hac vice)
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`e. Inter Partes Review Case IPR2016-01382 (admitted pro hac vice)
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`f. Reexamination Control No. 95/002,256, and related Appeal No. 2015-
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`006,133 (P.T.A.B)
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`g. Reexamination Control No. 95/001,504.
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`h. Reexamination Control No. 95/001,630.
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`5.
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`I am a member in good standing of the New York Bar. I have not had any
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`application denied for admission to practice, nor have I been sanctioned,
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`cited for contempt, suspended or disbarred from practice, before any court
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`or administrative body.
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`6.
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`I am familiar with the subject matter of this proceeding. I have reviewed
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`the subject U.S. Patent No. 6,959,293, as well as the petition for inter
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`partes review filed by Petitioner in this proceeding. I am counsel for Patent
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`Owner in the related, co-pending litigation.
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`7. Given my familiarity with the subject matter of this proceeding and my
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`experience, I have experience and expertise important to representing
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`Patent Owner Image Processing Technologies, LLC in this matter.
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`8.
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`I have read and will comply with the Office Patent Trial Practice Guide
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`and the Board's Rules of Practice for Trials set forth in part 42 of 37
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`C.F.R.
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`9.
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`I have read and will comply with and be subject to the United States
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`Patent and Trademark Office Rules of Professional Conduct set forth in
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`37 C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R.
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`§ 11.19(a).
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`10. I declare that all statements made herein of my knowledge are true and
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`that all statements made on information and belief are believed to be true,
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`and further that these statements are made with knowledge that willful
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`false statements and the like are punishable by fine or imprisonment, or
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`both, under § 1001 of Title 18 of the United States Code.
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`Executed on March 20, 2017
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`/s/ Mark A. Chapman
`Mark A. Chapman
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