`
`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
`
`Case IPR2017-00353
`Patent 8,983,134
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`
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`PATENT OWNER’S MOTION FOR PRO HAC VICE
`ADMISSION OF ROSE CORDERO PREY UNDER
`37 C.F.R. §42.10(c)
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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 submitted herewith as Exhibit 2005.
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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. IPR2017-00336
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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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`
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`proceeding.
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`Date: April 14, 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 April 14,
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`2017, the foregoing Patent Owner’s Motion for Pro Hac Vice Admission of Rose
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`Cordero Prey is being served via electronic mail upon the following counsel of
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`record for 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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`
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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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