IPR2017-00946
`Patent No. 7,268,703 B1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`FLIR SYSTEMS, INC. and
`FLIR MARITIME US, INC. (F/K/A RAYMARINE, INC.),
`Petitioner,
`
`v.
`
`GARMIN SWITZERLAND GmbH,
`Patent Owner.
`
`Case IPR2017-00946
`Patent No. 7,268,703 B1
`
`
`
`
`
`MOTION FOR PRO HAC VICE ADMISSION UNDER
`37 C.F.R. § 42.10
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`Patent No. 7,268,703 B1
`
`UNITED STATES PATENT AND TRADEMARK OFFICE
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`
`
`
`
`FLIR SYSTEMS, INC. and
`FLIR MARITIME US, INC. (F/K/A RAYMARINE, INC.),
`Petitioner,
`
`v.
`
`GARMIN SWITZERLAND GmbH,
`Patent Owner.
`
`Case IPR2017-00946
`Patent No. 7,268,703 B1
`
`
`
`
`
`MOTION FOR PRO HAC VICE ADMISSION UNDER
`37 C.F.R. § 42.10
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`
`IPR2017-00946
`Patent No. 7,268,703 B1
`
`
`PETITIONERS’ UPDATED EXHIBIT LIST – OCTOBER 24, 2017
`
`Exhibit
`
`Description
`
`FLIR-1001
`
`U.S. Patent No. 7,268,703 to Kabel et al. (“703 Patent”)
`
`FLIR-1002
`
`Prosecution File History of U.S. Patent No. 7,268,703
`
`FLIR-1003
`
`Declaration of Dr. Michael S. Braasch
`
`FLIR-1004
`
`Curriculum Vitae of Dr. Michael S. Braasch
`
`
`
`
`
`FLIR-1006
`
`FLIR-1007
`
`FLIR-1008
`
`FLIR-1009
`
`FLIR-1005 W.J. de Jong, Automated Route Planning – A Network-Based
`Route Planning Solution for Marine Navigation, University of
`Nottingham (December 2001) (“de Jong”)
`Tetley et al., Electronic Navigation Systems, 3d Ed.
`(Butterworth-Heinemann 2001) (“Tetley”) (excerpts)
`B. Brogdon, Boat Navigation for the Rest of Us, 2d Ed.,
`Introduction (McGraw-Hill 2001) (“Brogdon”) (excerpts)
`Fernão Vaz Dourado, Map of West Africa Waterways (circa
`1571)
`National Oceanic and Atmospheric Administration, Nautical
`Chart 25664 (1976) (Puerto Rico)
`National Oceanic and Atmospheric Administration, Nautical
`Chart 12283-02 (1990) (Annapolis Harbor)
`International Maritime Organization, Resolution A.817(19),
`Performance Standards for Electronic Chart Display and
`Information Systems (ECDIS) (Dec. 15, 1996)
`U.S. Patent No. 6,356,837 to Yokota et al. (“Yokota”)
`
`FLIR-1010
`
`FLIR-1011
`
`FLIR-1012
`
`FLIR-1013 Wan Xiaoxia et al., Electronic chart display and
`information system, Geo-spatial Information Science, 5:1, 7-11
`(Mar. 5, 2002) (“Xiaoxia”)
`Declaration of Christine Middleton and attachments
`
`FLIR-1014
`
`FLIR-1015
`
`Declaration of Dr. Scott Bennett and attachments
`
`2
`
`
`
`
`
`IPR2017-00946
`Patent No. 7,268,703 B1
`Exhibit
`Description
`
`FLIR-1016
`
`Declaration of Martijn van der Drift
`
`FLIR-1017
`
`FLIR-1018
`
`Hein Sabelis, Voyage Planning in ECDIS, International
`Hydrographic Review, Monaco, LXXVI(2) (September 1999)
`Nathaniel Bowditch, The American Practical Navigator,
`National Imagery and Mapping Agency, U.S. Government
`(2002 Bicentennial Edition) (excerpts)
`Encyclopedia of Electronics, 2d Ed. (McGraw-Hill 1990)
`(excerpts)
`Encyclopedia of Electronics, 2d Ed. (McGraw-Hill 1990)
`(excerpts from Library of Congress copy)
`Complaint filed in Garmin Switzerland GmbH and Garmin
`Corp. v. FLIR Maritime US, Inc. (f/k/a Raymarine, Inc.), Case
`No. 16-2806 (D. Kansas)
`Garmin’s Opposition to FLIR’s Motion to Dismiss the
`Complaint dated February 8, 2017 filed in Case No. 16-2806 (D.
`Kansas)
`EXHIBIT 1023 Declaration of Stephen Bosco
`
`FLIR-1019
`
`FLIR-1020
`
`FLIR-1021
`
`FLIR-1022
`
`EXHIBIT 1024 Biography of Stephen Bosco
`
`
`
`Petitioner FLIR Systems, Inc. and FLIR Maritime US, Inc. (collectively,
`
`“Petitioner”) file this motion for pro hac vice admission under 37 C.F.R. §
`
`42.10(c), as authorized in the Notice of Filing Date Accorded to Petition, Paper No.
`
`5. The Board requires that such motions be filed in accordance with the “Order –
`
`Authorizing Motion for Pro Hac Vice Admission” in Case IPR2013-00639, Paper 7
`
`(“Order”).
`
`
`
`3
`
`
`
`
`
`IPR2017-00946
`Patent No. 7,268,703 B1
`Petitioner respectfully requests that the Board recognize Mr. Stephen P.
`
`
`
`
`
`
`
`
`
`Bosco as counsel pro hac vice during this proceeding.
`
`1.
`
`Time for Filing
`
`This motion for pro hac vice admission is filed no sooner than twenty-one
`
`(21) days after service of the petition, as required by the Order.
`
`2.
`
`Statement of Facts
`
`The following statement of fact shows that there is good cause for the Board to
`
`recognize Mr. Bosco pro hac vice.
`
`Mr. Bosco has four years of experience as a patent litigaton attorney, and
`
`represents FLIR in the parallel district court litigation involving the patent challenged
`
`in this proceeding. Mr. Bosco’s biography is attached hereto as Ex. 1024. Mr. Bosco
`
`has previously litigated patent cases involving navigation technology and route
`
`planning. Prior to becoming an attorney, moreover, Mr. Bosco was a commissioned
`
`Surface Warfare officer in the U.S. Navy. During his naval service he received
`
`extensive training on, and hands-on experience with, marine navigation technology,
`
`and he utilized such technology as Officer-of-the-Deck responsible for the safe
`
`navigation of a U.S. Navy frigate.
`
`Further, counsel for Patent Owner does not oppose Mr. Bosco appearing
`
`pro hac vice during this proceeding.
`
`
`
`
`
`
`
`4
`
`
`
`
`
`
`
`IPR2017-00946
`Patent No. 7,268,703 B1
`Affidavit or Declaration of Individual Seeking to Appear
`3.
`
`This Motion for Pro Hac Vice Admission is accompanied by the declaration
`
`of Mr. Stephen Bosco, attached as Ex. 1023, as required by authorization of the
`
`Board.
`
`Dated: October 24, 2017
`
`Respectfully submitted,
`
`
`
`/ Brian E. Ferguson /
`Brian E. Ferguson (Reg No. 36,801)
`Anish R. Desai (Reg. No. 73,760)
`Weil, Gotshal & Manges LLP
`1300 Eye Street NW, Suite 900
`Washington, DC 20005
`T: 202-682-7000
`brian.ferguson@weil.com
`anish.desai@weil.com
`
`
`5
`
`
`
`
`
`
`
`
`
`
`IPR2017-00946
`Patent No. 7,268,703 B1
`
`CERTIFICATE OF SERVICE
`
`The undersigned hereby certifies that on October 24, 2017, the foregoing
`
`Motion for Pro Hac Vice Admission Under 37 C.F.R. § 42.10, Exhibits 1023-
`
`24, and Petitioners’ Updated Exhibit List was served via electronic mail, upon the
`
`following:
`
`
`
`
`
`
`
`Jennifer C. Bailey (Reg. No. 52,583)
`Adam P. Seitz (Reg. No. 52,206)
`ERISE IP, P.A.
`6201 College Blvd., Suite 300
`Overland Park, Kansas 66211
`(913) 777-5600
`jennifer.bailey@eriseip.com
`PTAB@eriseip.com
`adam.seitz@eriseip.com
`
`
`
`
`/ Timothy J. Andersen /
`Timothy J. Andersen
`Weil, Gotshal & Manges LLP
`1300 Eye Street NW, Suite 900
`Washington, DC 20005-3314
`timothy.andersen@weil.com
`
`
`
`
`
`
`
`
`
`
Accessing this document will incur an additional charge of $.
After purchase, you can access this document again without charge.
Accept $ Charge
Still Working On It
This document is taking longer than usual to download. This can happen if we need to contact the court directly to obtain the document and their servers are running slowly.
Give it another minute or two to complete, and then try the refresh button.
A few More Minutes ... Still Working
It can take up to 5 minutes for us to download a document if the court servers are running slowly.
Thank you for your continued patience.
This document could not be displayed.
We could not find this document within its docket. Please go back to the docket page and check the link. If that does not work, go back to the docket and refresh it to pull the newest information.
Your account does not support viewing this document.
You need a Paid Account to view this document. Click here to change your account type.
Your account does not support viewing this document.
Set your membership
status to view this document.
With a Docket Alarm membership, you'll
get a whole lot more, including:
- Up-to-date information for this case.
- Email alerts whenever there is an update.
- Full text search for other cases.
- Get email alerts whenever a new case matches your search.
One Moment Please
The filing “” is large (MB) and is being downloaded.
Please refresh this page in a few minutes to see if the filing has been downloaded. The filing will also be emailed to you when the download completes.
Your document is on its way!
If you do not receive the document in five minutes, contact support at support@docketalarm.com.
Sealed Document
We are unable to display this document, it may be under a court ordered seal.
If you have proper credentials to access the file, you may proceed directly to the court's system using your government issued username and password.
Access Government Site
