UNITED STATES PATENT AND TRADEMARK OFFICE
`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`TWITTER, INC.,
`Petitioner,
`
`v.
`
`YOUTOO TECHNOLOGIES, LLC,
`Patent Owner.
`_________________
`
`Case IPR2017-01131
`Patent 8,464,304
`_________________
`
`TWITTER, INC.’S UNOPPOSED MOTION FOR ADMISSION PRO
`HAC VICE OF ROBERT T. CRUZEN PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`
`
`_________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`_________________
`
`TWITTER, INC.,
`Petitioner,
`
`v.
`
`YOUTOO TECHNOLOGIES, LLC,
`Patent Owner.
`_________________
`
`Case IPR2017-01131
`Patent 8,464,304
`_________________
`
`TWITTER, INC.’S UNOPPOSED MOTION FOR ADMISSION PRO
`HAC VICE OF ROBERT T. CRUZEN PURSUANT TO 37 C.F.R. § 42.10(c)
`
`
`
`
`
`IPR2017-01131
`Patent 8,464,304
`
`
`LIST OF PREVIOUSLY FILED EXHIBITS
`
`Exhibits 1001-1019: Filed and served March 24, 2017 with Twitter’s Petition for
`
`Inter Parties Review of U.S. Patent No. 8,464,304.
`
`LIST OF NEWLY-FILED EXHIBITS
`
`Exhibit concurrently filed with Twitter’s Unopposed Motion for Admission Pro
`Hac Vice of Robert T. Cruzen:
`
`
`No.
`
`1020
`
`
`
`Description
`
`Declaration of Robert T. Cruzen
`
`Page i
`
`
`
`IPR2017-01131
`Patent 8,464,304
`
`
`I.
`
`INTRODUCTION
`
`Petitioner, Twitter, Inc. (“Twitter”) respectfully requests that the Board
`
`recognize Robert T. Cruzen as pro hac vice counsel for this proceeding. Patent
`
`Owner has indicated that it does not oppose.
`
`II. BACKGROUND
`
`Twitter’s Unopposed Motion for Pro Hac Vice Admission is being filed
`
`pursuant to and in compliance with the Notice of Filing Date Accorded to Petition
`
`and Time Period for Filing Patent Owner Preliminary Response, which was filed
`
`April 5, 2017 (Paper No. 3) (the “Notice”). The Notice authorizes the parties to file
`
`motions for pro hac vice admission under 37 C.F.R. § 42.10(c). Further to the Notice,
`
`such “motions shall be filed in accordance with the ‘Order – Authorizing Motion for
`
`Pro Hac Vice Admission’ in Case IPR2013-00639, Paper 7” (the “Order”).
`
`III. TIME OF FILING
`
`This Unopposed Motion for Pro Hac Vice admission is being filed in
`
`accordance with the Notice Authorizing the Filing of a Motion for Pro Hac Vice
`
`admission, and is filed greater than 21 days after that Notice.
`
`IV. STATEMENT OF FACTS
`
`As required by the Order, the following statement of facts, supported by the
`
`attached Declaration of Robert T. Cruzen in Support of Motion for Pro Hac Vice
`
`Admission (Ex. 1020), shows that there is good cause for the Patent Trial and Appeal
`
`Twitter, Inc.’s Unopposed Motion for
`Admission Pro Hac Vice of Robert T. Cruzen
`
`Page 1
`
`
`
`IPR2017-01131
`Patent 8,464,304
`
`Board (“Board”) to recognize Mr. Cruzen’s pro hac vice in this proceeding. As
`
`required by 37 C.F.R. § 42.10(c), lead counsel, Todd Siegel, is a registered
`
`practitioner experienced in proceedings before the USPTO.
`
`Mr. Cruzen is an experienced litigation attorney. Mr. Cruzen has been
`
`litigating intellectual property disputes for more than 18 years, and has been
`
`involved in numerous patent litigation cases in federal courts. Mr. Cruzen’s
`
`experience includes representing a wide range of clients in complex intellectual
`
`property litigation. Mr. Cruzen is a member in good standing of the Oregon State
`
`Bar and the California State Bar, with no suspensions or disbarments from practice,
`
`nor any application for admission to practice denied, nor any sanctions or contempt
`
`citations, and is admitted to practice in the United States Court of Appeals for the
`
`Federal Circuit. His mailing address is Klarquist Sparkman, LLP, 121 SW Salmon
`
`Street, Suite 1600, Portland, Oregon, 97204, his email address
`
`is
`
`rob.cruzen@klarquist.com, and his phone number is (503) 595-5300.
`
`Mr. Cruzen has worked with lead counsel in most aspects of this proceeding.
`
`As such, Mr. Cruzen has reviewed and is very familiar with (i) U.S. Patent No.
`
`8,464,304, the patent at issue in this proceeding, (ii) the prior art relied upon in
`
`Twitter’s Petition, (iii) the legal and factual arguments that have been addressed by
`
`Twitter, and (iv) the developments in this proceeding since the filing of Twitter’s
`
`Petition, as well as the developments in related matters before the Board.
`
`Twitter, Inc.’s Unopposed Motion for
`Admission Pro Hac Vice of Robert T. Cruzen
`
`Page 2
`
`
`
`IPR2017-01131
`Patent 8,464,304
`
`Accordingly, he has established familiarity with the subject matter at issue in these
`
`proceedings and the conduct of these proceedings to date.
`
`Mr. Cruzen has read and will comply with the Office Patent Trial Practice
`
`Guide and the Board’s Rules for Practice for Trials set forth in part 42 of 37 C.F.R.,
`
`and he agrees to be subject to the USPTO Rules of Professional Conduct set forth in
`
`37 C.F.R. §§11.01 et seq., and to disciplinary jurisdiction under 37 C.F.R. §11.19(a).
`
`Twitter’s Motion for Pro Hac Vice Admission is accompanied by a
`
`Declaration of Robert T. Cruzen (Ex. 1020) as required by the Order.
`
`V. ANALYSIS
`
`The facts described above and in the Cruzen Declaration (Ex. 1020) establish
`
`that there is good cause to admit Mr. Cruzen pro hac vice in this proceeding under
`
`37 C.F.R. § 42.10(c). Lead counsel is a registered practitioner, Mr. Cruzen is an
`
`experienced litigating attorney, and Mr. Cruzen has an established familiarity with
`
`the subject matter at issue in these proceedings.
`
`VI. CONCLUSION
`
`Therefore, Twitter respectfully submits that there is good cause for the Board
`
`to recognize Mr. Cruzen as Pro Hac Vice during these proceedings.
`
`
`
`
`
`
`
`
`
`Respectfully submitted,
`
`Dated: October 18, 2017
`
`By: /Todd M. Siegel/
`Todd M. Siegel (Registration No. 73,232)
`todd.siegel@klarquist.com
`
`Twitter, Inc.’s Unopposed Motion for
`Admission Pro Hac Vice of Robert T. Cruzen
`
`Page 3
`
`
`
`IPR2017-01131
`Patent 8,464,304
`
`
`KLARQUIST SPARKMAN, LLP
`One World Trade Center, Suite 1600
`121 S.W. Salmon Street
`Portland, Oregon 97204
`Tel: 503-595-5300
`Fax: 503-595-5301
`
`
`
`Twitter, Inc.’s Unopposed Motion for
`Admission Pro Hac Vice of Robert T. Cruzen
`
`Page 4
`
`
`
`IPR2017-01131
`Patent 8,464,304
`
`
`CERTIFICATE OF SERVICE
`IN COMPLIANCE WITH 37 C.F.R. § 42.6(e)(4)
`
`The undersigned certifies that on October 18, 2017, a true and correct copy of
`
`Twitter, Inc.’s Unopposed Motion for Admission Pro Hac Vice of Robert T.
`
`Cruzen and Exhibit 1020 was served on counsel for Youtoo Technologies, LLC
`
`Spencer C. Patterson
`Grable Martin Fulton PLLC
`1914 Skillman St., Ste. 110-144,
`Dallas, TX 75206
`Tel: 214- 396-8601
`Fax: 214- 988-0775
`Email: spatterson@gchub.com
`
`
`
`via electronic mail as follows:
`
`Scott McKeown
`Oblon, McClelland, Maier
` & Neustadt, LLP
`1940 Duke Street
`Alexandria, Virginia 22314
`Tel: 703-412-6297
`Fax: 703-413-2220
`Email: cpdocketmckeown@oblon.com
`
`Stephen L. Levine
`Carrington, Coleman, Sloman &
` Blumenthal, L.L.P.
`901 Main Street, Suite 5500
`Dallas, Texas 75202
`Tel: 214-855-3025
`Fax: 214-855-1333
`Email: slevine@ccsb.com
`
`
`By
`
`/Todd M. Siegel/
`Todd M. Siegel, Reg. No. 73,232
`todd.siegel@klarquist.com
`KLARQUIST SPARKMAN, LLP
`One World Trade Center, Suite 1600
`121 S.W. Salmon Street
`Portland, Oregon 97204
`Telephone: (503) 595-5300
`Facsimile: (503) 595-5301
`
`CERTIFICATE OF SERVICE
`
`
`
`Page 1
`
`
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