`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
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`KAWASAKI RAIL CAR, INC.
`Petitioner,
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`v.
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`SCOTT BLAIR,
`Patent Owner.
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`
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`Case No. IPR2017-01036
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`Patent No. 6,700,602
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`Issue Date: March 2, 2004
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`Title: Subway TV Media System
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`
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`MOTION FOR PRO HAC VICE ADMISSION
`OF MARK A. CHAPMAN
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`Pursuant to 37 C.F.R. § 42.10(c), Petitioner Kawasaki Rail Car, Inc.
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`respectfully requests the pro hac vice admission of Mark A. Chapman as backup
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`counsel for Petitioner in this proceeding. Patent Owner does not oppose this
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`Motion. A declaration made by Mark A. Chapman in support of this motion is
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`submitted herewith as Exhibit 1033.
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`I.
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`STATEMENT OF FACTS
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`1. Mr. Chapman is a partner at the law firm of Andrews Kurth Kenyon
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`LLP.
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`2. Mr. Chapman is a litigation attorney experienced in patent cases and
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`is a member in good standing of the New York Bar. He has not had any
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`application denied for admission to practice, nor has he been sanctioned,
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`cited for contempt, suspended or disbarred from practice, before any court or
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`administrative body.
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`3. Mr. Chapman has an established familiarity with the subject matter at
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`issue in this proceeding.
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`4.
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`In particular, Mr. Chapman has reviewed: the subject U.S. Pat. No.
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`6,700,602 (Ex. 1001); the Petition (Paper No. 2), the prior art references at
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`issue (Exs. 1005, 1009, 1011, 1021, 1025, 1026, 1028), and the declaration
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`and supplemental declaration of Petitioner’s expert (Exs. 1015, 1029); the
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`Patent Owner’s Preliminary Response (Paper No. 6), the Board’s Institution
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`- 1 -
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`Decision (Paper No. 10), the Patent Owner’s Response (Paper No. 15), and
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`the declarations and supplemental declaration of Patent Owner’s experts
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`(Exs. 2002, 2006, 2007); and the transcript of the deposition of Petitioner’s
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`expert (Ex. 2008).
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`5. Mr. Chapman has also discussed the strategy, arguments and evidence
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`in this proceeding with Ms. Mortazavi.
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`6.
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`In addition, Mr. Chapman has also applied for pro hac vice admission
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`to appear in Petitioner’s co-pending proceeding against Patent Owner, Inter
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`Partes Review Case No. IPR 2017-00117, in which a trial has been instituted
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`against additional claims of the same patent at issue in this proceeding. Mr.
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`Chapman has discussed the strategy, arguments and evidence in that related
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`proceeding with Ms. Mortazavi as well.
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`7.
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`The Motion for Pro Hac Vice Admission of Mr. Chapman in Case No.
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`IPR2017-00117 was filed on January 3, 2018. Patent Owner did not oppose
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`that motion either.
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`8.
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`In his declaration, Mr. Chapman also attests to each of the listed items
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`required by the Order – Authorizing Motion for Pro Hac Vice Admission –
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`37 C.F.R. § 42.10 in Unified Patents, Inc. v. Parallel Iron, LLC, IPR2013-
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`00639, Paper 7 at 2-4 (PTAB Oct. 15, 2013).
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`- 2 -
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`II. CONCLUSION
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`For the reasons stated above, Petitioner respectfully submits that there is
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`good cause for the Board to recognize Mark A. Chapman pro hac vice during this
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`proceeding.
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`Dated: January 5, 2018
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`Respectfully submitted,
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`/s/ Sheila Mortazavi
`Sheila Mortazavi (Reg. No. 43,343)
` Lead Counsel
`Zaed M. Billah (Reg. No. 71,418)
` Backup Counsel
`Armin Ghiam (Reg. No. 72,717)
` Backup Counsel
`Andrews Kurth Kenyon LLP
`One Broadway
`New York, NY 10004
`Telephone: (212) 425-7200
`Fax: (212) 425-5288
`Email:
`SheilaMortazavi@andrewskurthkenyon.com
`ZaedBillah@andrewskurthkenyon.com
`ArminGhiam@andrewskurthkenyon.com
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`- 3 -
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`CERTIFICATE OF SERVICE
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`The undersigned certifies that on January 5, 2018, a complete and entire
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`copy of this MOTION FOR PRO HAC VICE ADMISSION OF MARK A.
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`CHAPMAN and EXHIBIT 1033 were served via e-mail and Federal Express on
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`the following:
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`Jennifer Meredith
`jmeredith@meredithkeyhani.com
`205 Main Street
`East Aurora, New York 14052
`Tel: (212) 760-0098
`Fax: (212) 202-3819
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`Respectfully submitted,
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`/s/ Armin Ghiam
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`Armin Ghiam
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004
`Telephone: (212) 425-7200
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`- 4 -
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