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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 ROSE CORDERO PREY
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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 Rose Cordero Prey as backup counsel for Patent Owner in
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`the current proceedings. A declaration made by Ms. Prey in support of this motion
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`is attached hereto as Exhibit A.
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`1. Statement of Facts
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`1. Ms. Prey is a partner at the law firm of Andrews Kurth Kenyon LLP.
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`2. Ms. Prey is an experienced litigation attorney. Ms. Prey has been
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`litigating patent cases for over 10 years, and has experience litigating
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`patent infringement cases in many district courts and before the U.S.
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`International Trade Commission. Among her experience in patent
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`litigation matters, Ms. Prey has been counsel at trial, hearings, and with
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`respect to patent-related summary judgment proceedings and other
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`patent-related hearings and pleadings concerning, inter alia, patent
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`validity, claim construction, and infringement issues.
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`3. Ms. Prey received a Bachelor’s of Science degree in Mathematics, with
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`a minor in Physics, in 2001.
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`4. Ms. Prey has an established familiarity with the subject matter at issue
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`in this proceeding. Ms. Prey is trial counsel for Patent Owner and has
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`been actively involved in all aspects of the Eastern District of Texas
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`court proceeding against Petitioner involving the same patents and
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`technology (Image Processing Technologies, LLC v. Samsung
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`Electronics Co., Ltd., et al., 2:16-cv-00505-JRG).
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`5. Ms. Prey is a member in good standing of the State Bar of New York as
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`well as the United States District Court for the Eastern District of New
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`York, the United States District Court for the Southern District of New
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`York, the United States District Court for the Eastern District of Texas,
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`and the United States Court of Appeals for the Federal Circuit.
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`6. Ms. Prey has never been suspended or disbarred from practice before
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`any court or administrative body.
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`7. No application of Ms. Prey for admission to practice before any court or
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`administrative body has ever been denied.
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`8. No sanctions or contempt citations have been imposed against Ms. Prey
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`by any court or administrative body.
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`9. Ms. Prey has read and will comply with the Office Patent Trial Practice
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`Guide and the Board’s Rules of Practice for Trials set forth in part 42 of
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`Title 37 of the Code of Federal Regulations..
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`10. Ms. Prey understands that she will be subject to the USPTO Rules of
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`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et. seq. and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`11. Ms. Prey has applied to appear pro hac vice in three proceedings before
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`the United States Patent and Trademark Office in the last three (3)
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`years, Micron Technology, Inc. and Micron Memory Japan, Inc. v.
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`Massachusetts Institute of Technology, IPR2015-01087; Apple Inc., v.
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`Limestone Memory Systems LLC, IPR2016-01561; and Apple Inc. v.
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`Limestone Memory Systems LLC, IPR2016-01567.
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`12. Motions for Pro Hac Vice Admission of Ms. Prey 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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`2. Conclusions
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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 Rose Cordero Prey 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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`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 Rose Cordero Prey 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, Rose Cordero Prey, declare as follows:
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`1.
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`I am more than twenty-one years of age, am competent to present this
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`affidavit, and have personal knowledge of the facts set forth herein.
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`2. This affidavit is given in support of Image Processing Technologies, LLC’s
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`Motion for Pro Hac Vice Admission of Rose Cordero Prey under 37 C.F.R.
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`§ 42.10(c).
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`3.
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`4.
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`I am a partner at the law firm of Andrews Kurth Kenyon LLP.
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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. Mr. Coulson is lead
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`counsel on this case and is registered to practice in this Court.
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`5.
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`I am an experienced litigation attorney and have been litigating patent
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`cases for over 10 years. I have experience litigating patent infringement
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`cases in many district courts and before the U.S. International Trade
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`Commission. I have been counsel at trial, hearings, and with respect to
`
`patent-related summary judgment proceedings and other patent-related
`
`hearings and pleadings concerning, inter alia, patent validity, claim
`
`construction, and infringement issues. I have also been counsel in three
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`Inter Partes Review proceedings.
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`6.
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`I received a Bachelor’s of Science degree in Mathematics with a minor in
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`Physics in 2001.
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`7.
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`I am trial counsel for Patent Owner and have been actively involved in all
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`aspects of the Eastern District of Texas court proceeding against Petitioner
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`involving the same patents and technology (Image Processing
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`Technologies, LLC v. Samsung Electronics Co., Ltd., et al., 2:16-cv-00505-
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`JRG). Consequently I have gained in-depth familiarity with the subject
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`matter at issue in this proceeding.
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`8.
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`I have stayed up-to-date regarding the documents filed and actions taken to
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`date in the present matter (Case IPR2017-00336), and have carefully
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`reviewed it.
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`9.
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`I am a member in good standing of the State Bar of New York, as well as
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`the following Federal Courts:
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`United States District Court for the Eastern District of New York;
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`United States District Court for the Southern District of New York;
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`United States District Court for the Eastern District of Texas; and
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`United States Court of Appeals for the Federal Circuit.
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`10. I have never been suspended or disbarred from practice before any court or
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`administrative body.
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`11. I have never made an application for admission to practice before any court
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`or administrative body that has been denied.
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`12. No sanctions or contempt citations have been imposed against me by any
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`court or administrative body.
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`13. I have read and will comply with the Office Patent Trial Practice Guide and
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`the Board’s Rules of Practice for Trials set forth in part 42 of Title 37 of
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`the Code of Federal Regulations.
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`14. I understand that I will be subject to the USPTO Rules of Professional
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`Conduct as set forth in 37 C.F.R. §§ 11.101 et. seq. and disciplinary
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`jurisdiction under 37 C.F.R. § 11.19(a).
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`15. I have applied to appear pro hac vice in three proceedings before the
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`United States Patent and Trademark Office in the last three (3) years,
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`Micron Technology, Inc. and Micron Memory Japan, Inc. v. Massachusetts
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`Institute of Technology, IPR2015-01087; Apple Inc., v. Limestone memory
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`Systems LLC, IPR2016-01561; and Apple Inc. v. Limestone Memory
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`Systems LLC, IPR2016-01567.
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`16. Motions for Pro Hac Vice Admission of Ms. Prey are being concurrently
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`filed in the following related Inter Partes Review 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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`17. I declare that all statements made herein of my own 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 were made with the knowledge that
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`willful false statements and the like so made are punishable by fine or
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`imprisonment, or both, under Section 1001 of Title 18 of the United States
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`Code.
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`Executed on March 20, 2017
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`/s/ Rose Cordero Prey
`Rose Cordero Prey
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