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`UNITED STATES PATENT AND TRADEMARK OFFICE
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`BEFORE THE PATENT TRIAL AND APPEAL BOARD
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`SAMSUNG ELECTRONICS CO., LTD., and
`SAMSUNG ELECTRONICS AMERICA, INC.
`Petitioner
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`v.
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`IMAGE PROCESSING TECHNOLOGIES, LLC,
`Patent Owner
`
`Case IPR2017-01218
`Patent 8,983,134 B2
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`PATENT OWNER’S MOTION FOR PRO HAC VICE
`ADMISSION OF MICHAEL N. ZACHARY UNDER
`37 C.F.R. §42.10(c)
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`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner respectfully requests the pro
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`hac vice admission of Michael N. Zachary as backup counsel for Patent Owner in
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`the current proceedings. A declaration made by Mr. Zachary in support of this
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`motion is submitted herewith as Exhibit 2004.
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`1. Statement of Facts
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`1. Mr. Zachary is a litigation attorney experienced in patent cases, and is
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`admitted to practice law in California, Oregon, and Washington State, as
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`well as the following Federal Courts:
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`U.S. District Court for the Central District of California;
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`U.S. District Court for the Eastern District of California;
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`U.S. District Court for the Northern District of California;
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`U.S. District Court for the Southern District of California;
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`U.S. District Court for the District of Colorado;
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`U.S. District Court for the District of Oregon;
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`U.S. District Court for the Eastern District of Texas;
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`U.S. District Court for the Eastern District of Washington;
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`U.S. District Court for the Western District of Washington.
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`1
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`2. Mr. Zachary has not had any application denied for admission to practice,
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`nor has he been sanctioned, cited for contempt, suspended or disbarred
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`from practice, before any court or administrative body.
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`3. Mr. Zachary has an established familiarity with the subject matter at issue
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`in this proceeding, having represented Patent Owner in an Eastern
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`District of Texas court proceeding against Petitioner involving the same
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`technology (Image Processing Technologies, LLC v. Samsung
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`Electronics Co., Ltd., et al., 2:16-cv-00505-JRG).
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`4. Mr. Zachary has read and will comply with the Office Patent Trial
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`Practice Guide and the Board’s Rules of Practice for Trials set forth in
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`part 42 of the C.F.R.
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`5. Motion for Pro Hac Vice Admission of Mr. Zachary is being
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`concurrently filed in IPR2017-01190 involving the same parties.
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`2. Conclusions
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`For the reasons stated above, Patent Owner respectfully submits that there is
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`good cause for the Board to recognize Michael N. Zachary pro hac vice during the
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`proceeding.
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`Date: January 8, 2018
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`
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`/s/ Chris J. Coulson
`Chris J. Coulson (Reg. No. 61,771)
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, New York 1004-1007
`Tel: (212) 425-7200
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`2
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`Fax: (212) 425-5288
`chriscoulson@andrewskurthkenyon.com
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`Michael Zachary (pro hac vice)
`MichaelZachary@andrewskurthkenyon.com
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`CERTIFICATE OF SERVICE
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`Pursuant to 37 C.F.R. § 42.6(e), the undersigned certifies that on January 8,
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`2018, the foregoing Patent Owner’s Motion for Pro Hac Vice Admission of
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`Michael N. Zachary is being served via electronic mail upon the following counsel
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`of record for Petitioner:
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`John Kappos (Reg. No. 37,861)
`jkappos@omm.com
`O’Melveny & Myers LLP
`610 Newport Center Drive, 17th Floor
`Newport Beach, CA 92660
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`Marc J. Pensabene (Reg. No. 37,416)
`mpensabene@omm.com
`O’Melveny & Myers LLP
`Times Square Tower
`7 Times Square
`New York, NY 10036
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`Nicholas J. Whilt (Reg. No. 72,081)
`nwhilt@omm.com
`Brian M. Cook (Reg. No. 59,356)
`bcook@omm.com
`Clarence Rowland (Reg. No. 73,775)
`crowland@omm.com
`O’Melveny & Myers LLP
`400 South Hope Street, 18th Floor
`Los Angeles, CA 90071
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`IPTSAMSUNGOMM@OMM.COM
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`/s/ Chris J. Coulson
`Chris J. Coulson
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`Registration No. 61,771
`ANDREWS KURTH KENYON LLP
`One Broadway
`New York, NY 10004
`(212) 425-7200
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`Attorney for Patent Owner
`Image Processing Technologies, LLC
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`5
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