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`UNITED STATES PATENT AND TRADEMARK OFFICE
`____________
`
`BEFORE THE PATENT TRIAL AND APPEAL BOARD
`____________
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`PFIZER, INC., and
`SAMSUNG BIOEPIS CO., LTD.,1
`Petitioners,
`
`v.
`
`GENENTECH, INC.,
`Patent Owner,
`____________
`Case IPR2017-01488
`Patent 6,407,213
`
`____________
`
`
`PETITIONER’S MOTION FOR PRO HAC VICE
`ADMISSION OF SHARICK NAQI
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`
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`1 Samsung Bioepis Co. Ltd.’s IPR2017-02139 has been joined with this
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`proceeding. IPR2017-02139, Paper 42.
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`IPR2017-01488
`Petitioner’s Motion for Pro Hac Vice Admission of Sharick Naqi
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`TABLE OF CONTENTS
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`Page
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`
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`RELIEF REQUESTED ................................................................................... 1
`I.
`II. GOVERNING LAW, RULES, AND PRECEDENT ...................................... 1
`III. STATEMENT OF FACTS .............................................................................. 3
`A. Mr. Naqi Meets the Requirements for Pro Hac Vice Admission ......... 3
`IV. GOOD CAUSE EXISTS FOR THE PRO HAC VICE ADMISSION
`OF MR. NAQI IN THIS PROCEEDING ....................................................... 4
`CONCLUSION ................................................................................................ 5
`
`V.
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`
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`
`
`ii
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`IPR2017-01488
`Petitioner’s Motion for Pro Hac Vice Admission of Sharick Naqi
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`TABLE OF AUTHORITIES
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` Page(s)
`
`Cases
`United Patents, Inc. v. Parallel Iron, LLC,
`IPR2013-00639 Paper 7 (PTAB Oct. 15, 2013) ................................................... 2
`Other Authorities
`37 C.F.R. part 42 .................................................................................................... 2, 4
`37 C.F.R. § 11.19(a) ............................................................................................... 2, 4
`37 C.F.R. §§ 11.101 et. seq. ................................................................................... 2, 4
`37 C.F.R. § 42.10 ....................................................................................................... 5
`37 C.F.R. § 42.10(c) ............................................................................................... 1, 4
`
`iii
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`
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`IPR2017-01488
`Petitioner’s Motion for Pro Hac Vice Admission of Sharick Naqi
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`I.
`
`RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(c), Petitioner Pfizer, Inc., (“Petitioner”)
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`respectfully moves for the pro hac vice admission of Sharick Naqi in the above
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`proceeding.
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`II. GOVERNING LAW, RULES, AND PRECEDENT
`The Board is authorized to recognize counsel pro hac vice pursuant to 37
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`C.F.R. § 42.10(c), which provides that:
`
`The Board may recognize counsel pro hac vice during a proceeding
`upon a showing of good cause, subject to the condition that lead counsel
`be a registered practitioner and to any other conditions as the Board
`may impose. For example, 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.
`
`The Board has stated that a motion for admission pro hac vice must meet the
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`following requirements:
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`a. Contain a statement of facts showing there is good cause for the
`Board to recognize counsel pro hac vice during the proceeding.
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`b. Be accompanied by an affidavit or declaration of the individual
`seeking to appear attesting to the following:
`
`i. Membership in good standing of the Bar of at least one State
`or the District of Columbia;
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`1
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`IPR2017-01488
`Petitioner’s Motion for Pro Hac Vice Admission of Sharick Naqi
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`ii. No suspensions or disbarments from practice before any court
`or administrative body;
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`iii. No application for admission to practice before any court or
`administrative body ever denied;
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`iv. No sanctions or contempt citations imposed by any court or
`administrative body;
`
`v. The individual seeking to appear has read and will comply
`with the Office Patent Trial Practice Guide and the Board’s Rules
`of Practice for Trials set forth in part 42 of 37 C.F.R.;
`
`vi. The individual will be subject to the USPTO Rules of
`Professional Conduct set forth in 37 C.F.R. §§ 11.101 et. seq. and
`disciplinary jurisdiction under 37 C.F.R. § 11.19(a);
`
`vii. All other proceedings before the Office for which the
`individual has applied to appear pro hac vice in the last three (3)
`years; and
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`viii. Familiarity with the subject matter at issue in the proceeding.
`
`United Patents, Inc. v. Parallel Iron, LLC, IPR2013-00639 Paper 7 at 3–4 (PTAB
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`Oct. 15, 2013). See also IPR2017-01488 Paper 3 at 2 (PTAB Jun. 5, 2017) (“[Pro
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`hac vice] motions shall be filed in accordance with the ‘Order -- Authorizing Motion
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`for Pro Hac Vice Admission’ in Case IPR2013-00639, Paper 7, a copy of which is
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`available on the Board Web site under ‘Representative Orders, Decisions, and
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`Notices.’”).
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`2
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`IPR2017-01488
`Petitioner’s Motion for Pro Hac Vice Admission of Sharick Naqi
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`III. STATEMENT OF FACTS
`Based on the following facts, supported by his declaration, Petitioner
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`respectfully requests that Mr. Naqi be admitted pro hac vice in the proceeding. As
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`an initial matter, Petitioner’s lead counsel in the proceeding, Amanda Hollis
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`(No. 55,629), is a registered practitioner.
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`A. Mr. Naqi Meets the Requirements for Pro Hac Vice Admission
`1. Mr. Naqi has approximately five years of experience as a litigation attorney,
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`specializing in patent litigation. Mr. Naqi represents clients in patent litigation
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`matters in various United States District Courts. Mr. Naqi has experience with
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`numerous matters in the life sciences and pharmaceuticals arts, and he has
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`particular experience relevant to the technological and legal matters at issue in
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`the proceeding. Specifically, Mr. Naqi has represented a number of clients in
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`relation to monoclonal antibody therapies and methods of preparing antibodies.
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`2. Mr. Naqi is very familiar with U.S. Patent No. 6,407,213, with the legal subject
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`matter, technical subject matter, and prior art discussed in Petitioner’s Request
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`for Inter Partes Review. Mr. Naqi has personally reviewed the patent at issue,
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`as well as the prosecution history submission filed in this proceeding, and
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`accompanying declarations and exhibits.
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`3. Mr. Naqi is a member in good standing of the Bar of the State of Illinois.
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`3
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`IPR2017-01488
`Petitioner’s Motion for Pro Hac Vice Admission of Sharick Naqi
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`4. Mr. Naqi has never been suspended or disbarred from practice before any court
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`or administrative body.
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`5. Mr. Naqi has never had a court or administrative body deny an application for
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`admission to practice.
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`6. Mr. Naqi has never been sanctioned or cited for contempt by any court or
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`administrative body.
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`7. Mr. Naqi has read and will comply with the Office Patent Trial Practice Guide
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`and the Board’s Rules of Practice for Trials set forth in part 42 of 37 C.F.R.
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`8. Mr. Naqi agrees to be subject to the United States Patent and Trademark Office
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`Code of Professional Responsibility set forth in 37 C.F.R. §§ 11.101 et seq. and
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`disciplinary jurisdiction under 37 C.F.R. § 11.19(a).
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`9. Mr. Naqi has not been granted for pro hac vice admission in any proceedings
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`before the U.S. Patent and Trademark Office to date.
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`10. Petitioner has been informed that Patent Owner does not oppose this motion.
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`IV. GOOD CAUSE EXISTS FOR THE PRO HAC VICE ADMISSION OF
`MR. NAQI IN THIS PROCEEDING
`The Board may recognize counsel pro hac vice during a proceeding upon a
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`showing of good cause, subject to the condition that lead counsel be a registered
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`practitioner and any other conditions the Board may impose. 37 C.F.R. § 42.10(c).
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`4
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`IPR2017-01488
`Petitioner’s Motion for Pro Hac Vice Admission of Sharick Naqi
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`The facts contained in the Statement of Facts above, and contained in the Naqi
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`Declaration, establish that there is good cause to admit Mr. Naqi pro hac vice in the
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`proceeding under 37 C.F.R. § 42.10. Lead and back-up counsel include registered
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`practitioners, Mr. Naqi is an experienced litigation attorney, and Mr. Naqi has
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`familiarity with the subject matter at issue in the proceeding. Mr. Naqi has been, and
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`continues to be, actively involved with the strategy and fact development in this
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`matter. In view of Mr. Naqi’s extensive patent litigation experience and his
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`knowledge of the subject matter of the proceeding, the Petitioner has a substantial
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`need for Mr. Naqi’s pro hac vice admission and his involvement in the continued
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`prosecution of the proceeding.
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`V. CONCLUSION
`For the foregoing reasons, Petitioner respectfully requests that Sharick Naqi
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`be admitted pro hac vice.
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`Date: July 12, 2018
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`
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`
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`Respectfully submitted,
`
`/Amanda Hollis/
`Amanda Hollis
`Attorney for Petitioner Pfizer, Inc.
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`5
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`IPR2017-01488
`Petitioner’s Motion for Pro Hac Vice Admission of Sharick Naqi
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`CERTIFICATE OF SERVICE
`The undersigned hereby certifies that a copy of the foregoing Motion was
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`served on July 12, 2018, via electronic service on lead and back-up counsel:
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`For Genentech, Inc.:
`
`david.cavanaugh@wilmerhale.com
`lauren.blakely@wilmerhale.com
`robert.gunther@wilmerhale.com
`abrausa@durietangri.com
`ddurie@durietangri.com
`andrew.danford@wilmerhale.com
`kevin.prussia@wilmerhale.com
`lisa.pirozzolo@wilmerhale.com
`
`For Samsung Bioepis Co. Ltd.:
`ddrivas@whitecase.com
`sweingaertner@whitecase.com
`eric.majchrzak@whitecase.com
`athakore@whitecase.com
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`
`
`
`
`
`
` /Amanda Hollis/
`Amanda Hollis
`
`6
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