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`Reg. No. 42,557
`
`
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`_______________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`_____________
`
`INTEL CORPORATION, GLOBALFOUNDRIES U.S., INC.,
`
`MICRON TECHNOLOGY, INC., and
`
`SAMSUNG ELECTRONICS COMPANY, LTD.,
`
`
`
`
`
`
`
`Petitioners
`
`v.
`
`DANIEL L. FLAMM,
`
`Patent Owner
`
`CASE IPR2017-03921
`U.S. Patent No. 5,711,849
`
`
`PATENT OWNER’S UNOPPOSED MOTION FOR
`WITHDRAWAL AND SUBSTITUTION OF COUNSEL
`
`
`
`Mail Stop: PATENT BOARD
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
`
`1 Samsung Electronics Company, Ltd. was joined as a party to this proceeding via a
`Motion for Joinder in IPR2017-01747
`
`
`
`Inter Partes Review of U.S. Patent No. 5,711,849
`IPR2017-00392
`
`
`I.
`
`Relief Requested
`
`Pursuant to 37 C.F.R. § 42.10 and with the Board’s authorization for this
`
`motion by email dated February 28, 2018, Patent Owner Daniel L. Flamm (Flamm),
`
`by its attorney, respectfully requests that the board authorize withdrawal of
`
`Christopher Frerking as lead counsel, and appointment of Justin J. Lesko of the Law
`
`Offices of Steven G. Lisa, Ltd. as lead counsel and Rolf O. Stadheim of Stadheim &
`Grear, Ltd. as backup counsel in this proceeding.
`II.
`
`Statement of Facts Showing Good Cause for the Board to Authorize
`
`Withdrawal and Substitution of Counsel
`
`Patent owner’s new lead counsel is a registered practitioner (Reg. No. 69,643)
`
`and backup counsel is admitted pro hac vice by way of the Board’s Order dated
`
`February 16, 2018 (Paper 20) in this proceeding in accordance with 37 C.F.R. §
`
`42.10(c).
`
`In identifying and designating new counsel who are ready and able to take
`
`over the representation, reasonable steps have been taken to “avoid foreseeable
`
`prejudice to the rights of the client, including giving due notice to his or her client,
`
`[and] allowing time for employment of another practitioner.” See 37 C.F.R. §
`
`10.40(a). Further, Patent Owner believes that granting this motion will not hinder
`
`the economy, the integrity of the patent system, the efficient administration of the
`
`Office, or the ability of the Office to timely complete this proceeding. See 35 U.S.C.
`1
`
`
`
`
`
`Inter Partes Review of U.S. Patent No. 5,711,849
`IPR2017-00392
`
`
`§ 316(b).
`III. No Opposition to this Motion
`Patent Owner has confirmed with Petitioner that Petitioner does not oppose
`the present motion.
`
`IV. Conclusion
`Patent Owner respectfully requests that the Board grant its motion to authorize
`withdrawal of counsel and permit substitution of counsel. Upon grant of this motion,
`new counsel for Patent Owner will promptly file Amended Patent Owner’s
`Mandatory Notices and a Substitute Power of Attorney.
`
`Respectfully Submitted,
`
`By: /Christopher Frerking/
` Christopher Frerking, reg. no. 42,557
`
`174 Rumford Street
`Concord, New Hampshire 03301
`Telephone: (603) 706-3127
`Email: chris@ntknet.com
`
`Counsel for Daniel L. Flamm
`
`
`Date: February 28, 2018
`
`
`
`
`
`
`
`
`
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`
`
`2
`
`
`
`Inter Partes Review of U.S. Patent No. 5,711,849
`IPR2017-00392
`
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that the foregoing PATENT OWNER’S
`
`
`
`
`
`
`
`UNOPPOSED MOTION FOR WITHDRAWAL AND SUBSITUTION OF
`
`COUNSEL was served by electronic mail on this day, February 28, 2018, on the
`
`David M. Tennant
`dtennant@whitecase.com
`WHITE & CASE LLP
`701 Thirteenth St., NW
`Washington, DC 20005
`(202) 626-3600
`
`Nathan Zhang
`nathan.zhang@whitecase.com
`WHITE & CASE LLP
`3000 El Camino Real
`5 Palo Alto Square, 9th Floor
`Palo Alto, CA 94306
`(650) 213-0300
`
`WCGlobalFoundries-
`FlammTeam@whitecase.com
`
`Counsel for GLOBALFOUNDRIES
`U.S., Inc.
`
`following individuals:
`
`Jonathan McFarland
`JMcfarland@perkinscoie.com
`PERKINS COIE LLP
`1201 Third Ave., Suite 4900
`Seattle, WA 98101
`(206) 359-8000
`
`Daniel Keese
`DKeese@perkinscoie.com
`PERKINS COIE LLP
`1120 NW Couch St., 10th Floor
`Portland, OR 97209
`(503) 727-2000
`
`Chad S. Campbell
`CSCampbell@perkinscoie.com
`Tyler Bowen
`TBowen@perkinscoie.com
`PERKINS COIE LLP
`2901 North Central Ave., Suite 2000
`Phoenix, AZ 85012
`(602) 351-8000
`
`Intel-Flamm-Service-
`IPR@perkinscoie.com
`
`Counsel for Intel Corporation
`
`
`
`3
`
`
`
`Inter Partes Review of U.S. Patent No. 5,711,849
`IPR2017-00392
`
`
`
`
`Jared Bobrow
`Jared.bobrow@weil.com
`Jeremy Jason Lang
`jason.lang@weil.com
`WEIL, GOTSHAL & MANGES LLP
`201 Redwood Shores, CA 94065
`(650) 802-3000
`
`Micron.flamm.service@weil.com
`
`Counsel for Micron Technology, Inc.
`
`
`
`
`Naveen Modi
`naveenmodi@paulhastings.com
` Joseph E. Palys
`josephpalys@paulhastings.com
`Chetan R. Bansal
`chetanbansal@paulhastings.com
`Paul Hastings LLP
`875 15th Street, N.W.
`Washington, D.C. 20005
`(202) 551-1700
`
`PH-Samsung-Flamm-
`IPR@paulhastings.com
`
`Counsel for Samsung Electronics
`Company, Ltd.
`
`
`
`
`
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`
`
`
`
`By: /Christopher Frerking/
` Christopher Frerking, Reg. No. 42,557
`
`4
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