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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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`NETAPP, INC. and RACKSPACE US, INC.,
`Petitioners,
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`v.
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`REALTIME DATA LLC,
`Patent Owner.
`____________________
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`Case IPR2017-01660
`Patent No. 7,161,506
`____________________
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`MOTION FOR ADMISSION PRO HAC VICE OF
`KAYVAN B. NOROOZI
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`Mail Stop “PATENT BOARD”
`Patent Trial and Appeal Board
`U.S. Patent & Trademark Office
`P.O. Box 1450
`Alexandria, VA 22313-1450
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`Submitted Electronically via the PTAB E2E System
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`IPR2017-01660
`MOTION FOR ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI
`RELIEF REQUESTED
`Pursuant to 37 C.F.R. § 42.10(c), Patent Owner Realtime Data LLC
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`I.
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`(“Realtime”) respectfully requests that the Patent Trial and Appeal Board
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`admit Kayvan B. Noroozi pro hac vice in this proceeding.
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`II. GOVERNING LAW, RULES, AND PRECEDENT
`Section 42.10(c) provides that “where lead counsel is a registered
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`practitioner, a motion to appear pro hac vice by counsel who is not a
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`registered practitioner may be granted upon a showing that counsel is an
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`experienced litigating attorney and has established familiarity with the
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`subject matter at issue in the proceeding.”
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`III. STATEMENT OF FACTS
`The facts here satisfy § 42.10(c) and demonstrate good cause for the
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`Board to recognize Mr. Noroozi pro hac vice in this proceeding.
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`Lead counsel, William Rothwell, is a registered practitioner. Counsel,
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`Kayvan B. Noroozi, is an experienced patent litigator in good standing with
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`the California State Bar, admitted to practice before the United States
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`District Courts for the Eastern District of Texas and Northern District of
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`California, and has never been suspended, disbarred, sanctioned, cited for
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`contempt of court, or had a court or administrative body deny his application
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`for admission to practice. Ex. 2001 ¶¶ 1-5. Mr. Noroozi’s declaration
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`1
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`IPR2017-01660
`MOTION FOR ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI
`includes a list of the proceedings before the Office in which he has applied
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`to appear pro hac vice in the last three years. Id. at ¶ 6. Mr. Noroozi has read
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`and will comply with the Office Patent Trial Practice Guide and the Board’s
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`Rules of Practice for Trials set forth in part 42 of title 37 of the Code of
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`Federal Regulations. Id. at ¶ 7. Mr. Noroozi understands and accepts that he
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`will be subject to the USPTO Rules of Professional Conduct set forth in 37
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`C.F.R. §§ 11.101 et. seq. and disciplinary jurisdiction under 37 C.F.R. §
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`11.19(a). Id. at ¶ 8. Mr. Noroozi is familiar with the subject matter at issue in
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`this proceeding through his review of the underlying patent, the record, and
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`discussions with Patent Owner, its counsel, and its expert witness. Id. at ¶ 9.
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`IV. CONCLUSION
`For the foregoing reasons, Patent Owner respectfully requests that the
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`Board admit Kayvan B. Noroozi pro hac vice in this proceeding.
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`Respectfully submitted,
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`/s/ William Rothwell
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`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
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`Counsel for Patent Owner
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`2
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`Date: July 13, 2017
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`IPR2017-01660
`MOTION FOR ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI
`CERTIFICATION OF SERVICE
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`The undersigned hereby certifies that the foregoing MOTION FOR
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`ADMISSION PRO HAC VICE OF KAYVAN B. NOROOZI was served
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`electronically via e-mail on July 13, 2017, in its entirety on the following
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`counsel of record for Petitioner:
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`Diek O. Van Nort (Lead Counsel)
`Jonathan Bockman (Back-up Counsel)
`Kyle Howard (Back-up Counsel)
`David McCombs (Back-up Counsel)
`Greg Webb (Back-up Counsel)
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`kyle.howard.ipr@haynesboone.com
`david.mccombs.ipr@haynesboone.com
`greg.webb.ipr@haynesboone.com
`35667-506-IPR@mofo.com
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`Respectfully submitted,
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`/s/ William Rothwell
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`William P. Rothwell, Reg. No. 72,522
`NOROOZI PC
`2245 Texas Drive, Suite 300
`Sugar Land, TX 77479
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`Counsel for Patent Owner
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`Date: July 13, 2017
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`3
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