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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`COMPLEX INNOVATIONS, LLC,
`Petitioner,
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`v.
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`ASTRAZENECA AB,
`Patent Owner.
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`Case No. IPR2017-00631
`Patent No. 7,759,328
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`PATENT OWNER’S MOTION FOR
`WITHDRAWAL AND SUBSTITUTION OF COUNSEL
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` DC: 6347050-3
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`IPR2017-00631
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`I.
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`37 C.F.R. § 42.10 - STATEMENT OF RELIEF REQUESTED
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`Pursuant to 37 C.F.R. § 42.10(e), and the Board’s authorization dated March
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`20, 2017, Patent Owner AstraZeneca AB respectfully requests that the Board
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`authorize withdrawal of Jeffrey P. Kushan and Paul J. Zegger of Sidley Austin LLP
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`as lead and backup lead counsel, and to designate Christopher N. Sipes and Andrea
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`G. Reister of Covington & Burling LLP (“Covington”) as lead and backup lead
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`counsel, respectively.
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`II. STATEMENT SHOWING GOOD CAUSE FOR WITHDRAWAL AND
`SUBSTITUTION OF COUNSEL
`On January 9, 2017, Petitioner Complex Innovations, LLC filed a petition in
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`this proceeding. The Board accorded the petition a filing date of January 9, 2017 in
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`Paper No. 22, dated January 26, 2017.
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`On January 24, 2017, Patent Owner filed its mandatory notices in response to
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`the Petition. In that paper, Patent Owner appointed Jeffrey P. Kushan and Paul J.
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`Zegger of Sidley Austin LLP as lead and back-up counsel in this proceeding.
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`Patent Owner now wishes to designate Christopher N. Sipes as lead counsel
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`and Andrea G. Reister as backup lead counsel in this proceeding. Mr. Sipes and Ms.
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`Reister are each registered practitioners before the Office, and otherwise meet the
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`requirements of 37 C.F.R. § 42.10.
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`No actions have occurred in this proceeding beyond the filing of the petition,
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`the according of the petition of a filing date, and the filing of mandatory notices by
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`IPR2017-00631
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`Patent Owner. In view of the early stage of this proceeding, “[w]ithdrawal can be
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`accomplished without material adverse effect on the interests of the client.” 37
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`C.F.R. § 11.116(b)(1). Petitioner has indicated it does not oppose the withdrawal
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`and substitution of counsel for Patent Owner since Patent Owner is not seeking to
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`change the deadline for a preliminary response as a result. Finally, Patent Owner
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`believes that granting this motion will not hinder the economy, the integrity of the
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`patent system, the efficient administration of the Office, or the ability of the Office
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`to timely complete this proceeding. See 35 U.S.C. § 316(b).
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`III. CONCLUSION
`Patent Owner respectfully requests that the Board grant its motion to authorize
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`withdrawal of counsel and permit substitution of new lead and backup counsel.
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`Upon granting of this motion, new counsel for Patent Owner will promptly file a
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`new Power of Attorney and Updated Mandatory Notices.
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`Dated: March 21, 2017
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`Respectfully Submitted,
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`/Jeffrey P. Kushan/
`Jeffrey P. Kushan
`Reg. No. 43,401
`SIDLEY AUSTIN LLP
`1501 K Street NW
`Washington, DC 20005
`Attorney for Patent Owner
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6, I hereby certify that on this 21st day of March 2017,
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`the foregoing Patent Owner’s Motion for Withdrawal and Substitution of Counsel, was
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`served by electronic mail on the following counsel of record for petitioner.
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`Sharad K. Bijanki (sb@hkw-law.com)
`Vivek Ganti (vg@hkw-law.com)
`Hill, Kertscher & Wharton, LLP
`3350 Riverwood Parkway SE, Suite 800
`Atlanta, GA 30339
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` /s/ Jeffrey P. Kushan
`Jeffrey P. Kushan, Esq.
`Registration No.: 43,401
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`Date: March 21, 2017
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