UNITED STATES PATENT AND TRADEMARK OFFICE
`
`___________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________________________________
`
`INTEL CORP., and
`CAVIUM, INC.,
`Petitioner,
`
`v.
`
`ALACRITECH, INC.,
`Patent Owner.
`
`________________________
`
`Case IPR2017-013921
`Patent 7,337,241
`
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF KARINEH KHACHATOURIAN
`UNDER 37 C.F.R. § 42.10(c)
`
`1 Cavium, who filed a Petition in case IPR2017-01728, has been joined as a
`petitioner in this proceeding.
`
`
`
`___________________________________________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`
`___________________________________________
`
`INTEL CORP., and
`CAVIUM, INC.,
`Petitioner,
`
`v.
`
`ALACRITECH, INC.,
`Patent Owner.
`
`________________________
`
`Case IPR2017-013921
`Patent 7,337,241
`
`PETITIONER’S UNOPPOSED MOTION FOR PRO HAC VICE
`ADMISSION OF KARINEH KHACHATOURIAN
`UNDER 37 C.F.R. § 42.10(c)
`
`1 Cavium, who filed a Petition in case IPR2017-01728, has been joined as a
`petitioner in this proceeding.
`
`
`
`IPR2017-01392
`Motion for Pro Hac Vice Admission of Karineh Khachatourian
`
`I.
`
`STATEMENT OF PRECISE RELIEF REQUESTED
`
`Pursuant to 37 C.F.R. § 42.10(c) authorizing the petitioner to file motions
`
`for pro hac vice admission under 37 C.F.R. § 42.10(c), Cavium, Inc. requests that
`
`the Patent Trial and Appeal Board (the “Board”) admit Karineh Khachatourian pro
`
`hac vice in this proceeding, IPR2017-01392.
`
`II.
`
`STATEMENT OF FACTS SHOWING GOOD CAUSE FOR THE
`BOARD TO RECOGNIZE COUNSEL PRO HAC VICE DURING THE
`PROCEEDING
`
`In accordance with 37 C.F.R. § 42.10(c), the Board may recognize counsel
`
`pro hac vice subject to the condition that lead counsel be a registered practitioner
`
`and to any other conditions that the Board may impose. Section 42.10(c) provides
`
`that “where the lead counsel is a registered practitioner, a motion to appear pro hac
`
`vice by counsel who is not a registered practitioner may be granted upon showing
`
`that counsel is an experienced litigating attorney and has an established familiarity
`
`with the subject matter at issue in the proceeding.” See also Unified Patents v.
`
`Parallel Iron, IPR2013-00639, Paper 7 (Oct. 15, 2013). The following facts
`
`establish good cause for the Board to recognize Karineh Khachatourian pro hac
`
`vice in this proceeding:
`
`1.
`
`I, Patrick D. McPherson, backup counsel in this proceeding, am a
`
`registered practitioner.
`
`
`
`IPR2017-01392
`Motion for Pro Hac Vice Admission of Karineh Khachatourian
`
`2.
`
`Ms. Khachatourian is an experienced patent litigator, and has
`
`established familiarity with the subject matter at issue in this proceeding from her
`
`participation in co-pending litigation involving the subject patent. Specifically,
`
`U.S. Patent No. 7,337,241 B2 is currently asserted against Petitioner in co-pending
`
`litigation, in the Eastern District of Texas, Alacritech, Inc. v. Dell Inc., Case No.
`
`2:16-cv-00695 (filed Jun. 30, 2016) (“the co-pending litigation”). Ms.
`
`Khachatourian is a member of the California Bar in good standing, has been
`
`representing the Petitioner as lead counsel in the co-pending litigation since its
`
`inception and has been actively involved in all aspects of the case. Other than Ms.
`
`Khachatourian’s co-pending application for pro hac vice admission in IPR Trial
`
`Nos. IPR2017-01391, IPR2017-01393, IPR2017-01405, IPR2017-01406,
`
`IPR2017-01409, and IPR2017-01410 and IPR Trial Nos. IPR2015-01595,
`
`IPR2015-01078, IPR2015-01080, IPR2017-01071 and IPR2017-01070, Ms.
`
`Khachatourian has not applied to appear pro hac vice in any other Board, or United
`
`States Patent and Trademark Office (“USPTO”) proceeding, over the last three
`
`years.
`
`3.
`
`As part of her participation in co-pending litigation involving the
`
`subject patent, Ms. Khachatourian has analyzed prior art references related to the
`
`claimed inventions, all of which are relevant to the petition requesting inter partes
`
`review of U.S. Patent No. 7,337,241 B2. Petitioner wishes to apply Ms.
`
`2
`
`
`
`IPR2017-01392
`Motion for Pro Hac Vice Admission of Karineh Khachatourian
`
`Khachatourian’s knowledge concerning the patent by employing her as counsel in
`
`this proceeding. Admission of Ms. Khachatourian pro hac vice will enable
`
`Petitioner to avoid unnecessary expense and duplication of work between this
`
`proceeding and the co-pending litigation.
`
`4.
`
`Petitioner’s counsel, Patrick D. McPherson, is a registered practitioner
`
`and Ms. Khachatourian is an experienced patent litigation attorney having
`
`established familiarity with the subject matter at issue in this proceeding.
`
`Therefore, Petitioner respectfully submits that there is good cause for the Board to
`
`recognize Ms. Khachatourian as counsel pro hac vice during this proceeding.
`
`5.
`
`This Motion for Pro Hac Vice Admission is supported by a
`
`Declaration of Ms. Khachatourian (Exhibit A).
`
`6.
`
`Counsel for Patent Owner does not oppose Ms. Khachatourian
`
`appearing pro hac vice during this proceeding.
`
`3
`
`
`
`IPR2017-01392
`Motion for Pro Hac Vice Admission of Karineh Khachatourian
`
`III. CONCLUSION
`
`For the foregoing reasons, Petitioner respectfully requests that the Board
`
`admit Karineh Khachatourian pro hac vice in this proceeding.
`
`Respectfully submitted,
`
`Cavium, Inc.,
`Petitioner
`
`Tel: (202) 776-7800
`Fax: (202) 776-7801
`
`Dated: February 14, 2018
`
`By: /Patrick D. McPherson/
`Patrick D. McPherson
`Registration No. 46,255
`Duane Morris LLP
`
`4
`
`
`
`IPR2017-01392
`Motion for Pro Hac Vice Admission of Karineh Khachatourian
`
`CERTIFICATE OF SERVICE
`
`Pursuant to 37 C.F.R. § 42.105, I hereby certify that I caused a true and
`
`correct copy of the Petitioner’s Unopposed Motion for Pro Hac Vice of Karineh
`
`Khachatourian, and associated Exhibit A, via PTAB E2E and email to the
`
`following:
`
`Jim Glass
`jimglass@quinnemanuel.com
`
`Joseph Paunovich
`joepaunovich@quinnemanuel.com
`
`Brian Mack
`brianmack@quinnemanuel.com
`
`Dated: February 14, 2018
`
`/ Susan Griffin
`
` /
`
`
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